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I dont think they have, but they should.
Its like the whole "Pete Rose not being in the Hall of Fame" issue. People want him in the Hall, but not to have an induction speech and all that. Have his recognition, but still let it be known that you can't get away with your crimes.
Thats how it should be with Benoit, at least by his name. They should be able to say "Orton won his first WWE Title by beating Chris Benoit at Summerslam in 2004". Nothing more, nothing less.
MAYBE I recall in a HOF ceremony someone mentioned "Chris" or "Benoit", maybe on the internet broadcast or TV broadcast, but I can't say for certain...but for some reason it popped into my head.
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