Crossword Genius

Holds title to (3)

Ross

I think it could be either:

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3

4

has

'holds title to' is the definition.
(I've seen this in another clue)

This is the entire clue.

(Other definitions for has that I've seen before include "Eats" , "Gives birth to" , "Enjoys" , "Cheats" , "Contains" .)

I've seen this clue in the Penny Press.
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