Bawylie
A very OK person
Sounds like there should be some discussion about the stakes before the roll, then.I ask if I can recall hearing this name before. DM calls for a History (Intelligence) check. So whether I succeed or fail at that check, DM is going to rule that I DO recall the name and know who she is. Unbeknownst to me, what I am apparently actually doing is making an Intelligence (History) check to see if I succeed on a Charisma (Deception) check. Yeah, that sort of thing is going to annoy me. So much so that I would tend to shut down and avoid making any skill checks at all if I can help it, since the results are likely to be wholly unrelated to what I was trying to do. In this case, what if my character is a professional charlatan with expertise in Deception? I'm still going to drop my poker face while trying to remember a name?
I might not want to risk the fail conditions that tip off the NPC. And as you point out, you weren’t setting out to bluff.
Nevertheless, the thread isn’t about A POSSIBLE fail condition on an Int check. Iserith’s broader point, as I read it, is that there are various ways forward from knowing the NPC is a villain.