It's really busy, you need to have a foci and use the negative space to draw the eye. The elbow portions are so busy with detail i can't tell whats going inside. The hand on the book is similarly slate colored with the cover with thick line work that the hand disappears into he design. The gold inlay in the coat/dress/veil has no light source indications. Again drawing the eye unnecessarily to the portions of the picture that detract from whats probably the focal point.
I see beginning of shadow work however the absence of gradient work makes portions of the picture look like a cutout instead 3 dimensional or full bodied. Take the hem of the skirt and the top of the legs, the single tonal shadow without what one expects on a round leg: a gradient shadow growing heavier as you travel to the inner thigh; Without that indicator it just look like paper layers onto of paper layers.
The bottom of the legs (or chins) has what seems like high lighting on either side of the chin, again contrary to where the light source seems to be emanating from.
Great design overall, really good detail. However its in that state where it's in an uncanny valley of sorts.
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