This blog post is incomplete with respect to Breyer. An IP address is always personal data to an ISP. It's also personal data to anyone who can ask/request/comp

This blog post is incomplete with respect to Breyer. An IP address is always personal data to an ISP. It's also personal data to anyone who can ask/request/compel the ISP to identify someone based on the IP address. And one of the main conclusions of Breyer is that only happens in an obscure edge-case scenario, that's enough for IP addresses to be considered personal data all the time. The case specifically was that in the local jurisdiction, there's a law that if a company gets DDOSed they can request the local regulator to ask the ISP to identify a user. This law only gets triggered in very exceptional circumstances, but its existence means that IP addresses are always personal data in that jurisdiction. While that law only covers one part of Germany, the analysis applies to any similar law, of which it is safe to assume there are many.