  CoGeNT and MALBEK use p-type point contact germanium detectors to search for
low-mass dark matter particles. Both detectors enjoy identical intrinsic noise
characteristics. However, MALBEK's data acquisition electronics severely
degrade the ability to separate signals originating in the bulk of the
germanium crystal from surface backgrounds, through a measurement of the
preamplifier pulse rise-time in the sub-keVee energy range of interest. The
physical meaning of the parameter W$_{par}$ developed by the MAJORANA
collaboration to compensate for this limitation is clarified here. It is shown
that this parameter does not correlate to rise-time at low energy, and is
presently unable to distinguish between surface and bulk events below $\sim$1
keVee. This leads to a sizable overstatement of MALBEK's sensitivity to
low-mass dark matter particles, when employing aggressive W$_{par}$ cuts.
