Li v. Ashcroft, 389 F.3d 892 (9th Cir. Nov. 19. 2004) ("Potential or intended loss can satisfy the second element under 8 U.S.C. 1101(a)(43)(U), which defines an aggravated felony as "an attempt or conspiracy to commit" another aggravated felony defined in 1101(a)(43). See In re Onyido, 22 I. & N. Dec. 552 (BIA 1999) (concluding that submission of a false insurance claim qualified as an aggravated felony under 1101(a)(43)(U), even though the petitioner's scheme was unsuccessful and he received no payment from the insurance company).").