The term high-value is used twice in the ACME draft but is never defined. I think I understand what it means but in chatting with some others, there is at least one interpretation that high-value means phishing sites. If this is the correct definition, I suggest removing either the high-value or phishing bullet in section 10.5 or including a note to affirm these terms are synonymous. Including a definition may be worthwhile in any case.
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