You are probably right. But someone could argue semantics. The project is for the express purpose of registering domain names. And the project only does querie

You are probably right. But someone could argue semantics. The project is for the express purpose of registering domain names. And the project only does queries as needed to verify domain ownership - falling under "reasonably necessary". IANAL so my opinion means very little, but it seems like the TOS are targeted towards people who want to abuse the system for doing things like mass data collection, spamming, and other "bad behaviors". Not someone who wants to make sure domains are available for registration. After all, how do the big players do it? Simply downloading the list of all valid domains even once a day would not be sufficient.