I would have said !-- is the tag name of that, though with the closing part requiring a double dash as well, it's rather unique and maybe not a proper tag... could have included it in a bonus list though, not counting it towards the total but showing it as a bonus entry at the top of your findings
Basically <!> was valid, and -- only served as the start and end of a comment, and between <! and > you could have multiple "comments", example from the rfc:
<!-- another -- -- comment -->
In the current spec it is basically defined as starts with "<!--" and closed by "-->".