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PSA seller has a duty to disclose all "material" facts. A material fact is one that, in layman's terms, significantly affects the total mix of information available. At first blush, one would think in certain cases grading history is obviously material. For example, a PSA 8 Ruth card that had been previously rejected twice by PSA itself and once by SGC for trimming. Then again, I am not sure buyers really care, as long as the card eventually is slabbed. One could cynically take the point of view that buyers know the games that are played and the fact that (except for Corey) no one seems to be demanding to know grading history shows they don't care.