Gaps: MLS-data inside-the-box brief (June 2026) — public-data register not located; counsel items

Open research items before this becomes an article:

1. Public-data register cross-check. The project's separate "Ontario real-estate data source register" — the OUTSIDE-the-box catalog — could not be located in Drive during the source session. Searches on MLS, HPI, land registry, StatsCan, Teranet, HouseSigma, absorption, days on market, Greater Golden Horseshoe all returned empty. Confirm the register's contents before finalising the seam in any published piece — either the register lives outside this Drive's indexed Google-Docs scope (e.g., Sheet, PDF, different shared drive), or under a name not matched.

2. Operative AUA/DLA text review. The PropTx AUA s.7(c) clauses cited via 2019 litigation summary + Dec 2 2024 PropTx Rules may differ from the currently-signed agreement. Pull the version actually in force for any builder context.

3. Counsel review on the "analyze" word. PropTx AUA s.7(c)'s prohibition on creating derivative works of, or "analyzing," the MLS Database is the single most dangerous clause for an analytics product. Get a written opinion before any product asserts it does not breach this.

4. Counsel review on de-identification threshold. When sufficiently aggregated MLS data stops being "about an identifiable individual" for PIPEDA purposes is fact-specific and not bright-line. The OPC #2009-004 analogy (OPC PIPEDA Case #2009-004 — combining publicly available directory info with geo-demographic stats did NOT create new personal info requiring consent; by analogy, sufficiently aggregated/de-identified MLS market stats likely fall outside PIPEDA consent (DS for the threshold)) is DS for the MLS-aggregate application — counsel review essential.

5. Counsel review on the agent-permissioned (Redatum) seam. The 2021 FC 30 outcome was injunction-denied, not merits-decided. Subsequent feed-eligibility cases (Ojohome Canada Ltd. v. CREA / TRREB (2025, Ont. Sup. Ct.) — TRREB terminated IDX access Oct 2024; CREA restricted DDF Dec 2024; site cut from ~54,000 to ~11,500 listings; injunction to restore access denied) show boards actively police this. Resilience to a board terminating feed eligibility must be built into the commercial model.

6. Independent verification of HouseSigma metrics. Self-reported user/visit figures are internally inconsistent; before citing as fact, verify against an independent source (Similarweb, etc.).

7. Verify Ontario board migration list. OMDREB, London, Ottawa, Niagara, KAREA, NAR, NBARA, WITAAR, OnePoint listed as moving to PropTx via realestatemagazine.ca; verify against primary board notices before relying on the migration list in a published piece.

8. Re-pull primary BDC and TRREB Market Watch sources. The "Month's Inventory" line is cited via practitioner blog; the actual TRREB Market Watch primary should be cited in any published piece.

9. Trace primary for "first in Canada to make sold prices publicly available." The HouseSigma framing is founder-attributed; primary verification before citing as fact.