Li v. Ashcroft, 389 F.3d 892, 897 (9th Cir. Nov. 19. 2004) (conviction of making a false claim against the United States, in violation of 18 U.S.C. 287, is divisible with respect to the fraud offense aggravated felony defined in INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), since even though it does require some intended loss, "no particular amount of intended loss is required," and so does not automatically satisfy the element of this aggravated felony definition requiring a loss to the victim(s) in excess of $10,000, so the record of conviction must be examined to determine whether the conviction falls within the definition).