In section 3.1 this is stated:
"On receiving a close performative on stream 0, an implementation MAY choose to continue reading messages until no more data is incoming. An implementation SHOULD limit the number of frames that it reads after receiving a close."

Clarify - are "frames" being received or "messages"? (second sentence)

Might it be advisable to limit frame receive to a period of time (possibly tied to historic ack rate or some such) rather than by number of frames?