(C)  Unintentional Loss.  In the federal criminal context, the Ninth Circuit ruled that the loss to the victim does not include losses attributable to intervening, unforeseeable, and independent crimes.[667]

[667] United States v. Hicks, 217 F.3d 1038 (9th Cir. 2000) (for purposes of calculating a fraud defendant’s offense level under the Sentencing Guidelines aggravated felony definition).