Nijhawan v. Attorney General, 523 F.3d 387 (3d Cir. May 2, 2008) ("In Dulal-Whiteway, the Second Circuit noted that the words of the INA provision render deportable one who has been convicted of an aggravated felony, not one who has committed an aggravated felony. Id. at 132. We do not disagree with this and, much like the Court of Appeals for the First Circuit in Conteh, we endorse careful consideration of the record to determine whether it is sufficiently clear that the loss connected to the crime of conviction exceeded $10,000. As Judge Becker noted in Singh, The dissent posits that our opinion permits consideration of loss caused by "relevant conduct" rather than the conduct of conviction. This is not correct. By requiring that loss be tethered to the convicted conduct, we are excluding consideration of relevant conduct, as did the Court of Appeals for the Seventh Circuit in Knutsen and the Court of Appeals for the Eleventh Circuit in Obasohan. In fact, we use the word "relevant" only in discussing these courts opinions. Furthermore, there is no conduct in this case other than that underlying the conviction."