Park v. Attorney General of the United States, ___ F.3d ___, 2006 WL 3821408 (3d Cir. Dec. 29, 2006) (federal conviction of trafficking in counterfeit goods or services in violation of the Trademark Counterfeiting Act of 1984, 18 U.S.C. 2320, is an aggravated felony conviction for "an offense relating to ... counterfeiting," under INA 101(a)(43)(R), 8 U.S.C. 1101(a)(43)(R)).