The Swimmer with Most Gold Medals

I don't even know what this question means.

Does it mean Olympic golds? I don't think so, because Michael Phelps has 23 of those. Does it mean Olympic titles? No, because he currently holds five – two individual and three relay. And anyway, you wouldn't describe a member of a relay team as "holding the title".

As well as the Olympics, Wikipedia lists World Championship and Pan Pacific Championship medals. Phelps has won, in total, 26 of the former and 16 of the latter (golds, that is, in both cases). That's 65 gold medals altogether, including his 23 Olympic ones.

So what's with the "3 individual, 4 relay"?

The only thing that can be said in favour of this question is that if they'd just asked which American swimmer has a lot of medals, the answer has got to be Michael Phelps.