Alaka v. Attorney General, ___ F.3d ___, 2006 WL 1994500 (3d Cir. Jul. 18, 2006) (in determining whether conviction constituted fraud offense aggravated felony, under INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), immigration court erred in considering amount of intended loss for all of the charges - including dismissed counts - rather than limiting loss to victim to the loss for the single count of conviction); accord, Knutsen v. Gonzales, 429 F.3d 733 (7th Cir. 2005); Khalayleh v. INS, 287 F.3d 978 (10th Cir. 2002); Chang v. INS, 307 F.3d 1185 (9th Cir. 2002).