The description of the Output message states that the payment request can specify any standard TxOut script, and that OP_RETURN is a standard transaction type that would imply the ability to specify OP_RETURN outputs in BIP 70 payment requests. If the creator of a payment request wanted the sender to include a small amount of data as an OP_RETURN output, how would they specify this? -- Support online privacy by using email encryption whenever possible. Learn how here: http://www.youtube.com/watch?v=bakOKJFtB-k