They may be on the coin. If this were a die issue, you just see them on the fields. But I notice I see them over the devices. So they maybe added to the coin? But They maybe from a damaged planchet. But We have seen this before and never had a definite answer on these.
To me, looks like degradation of the zinc core causing the copper plating to detach on the surface. If so, it's much more beautiful than it usually is, but definitely what it looks like to me.
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