Doe v. Attorney General, 659 F.3d 266 (3d Cir. Sept. 8, 2011) (in evaluating the amount of loss to the victim in excess of $10,000, necessary to establish an aggravated felony fraud offense, under INA 101(a)(43)(M)(i), 8 U.S.C. 1101(a)(43)(M)(i), a court must limit itself to consideration of the loss tethered to the alien's specific offense of conviction.); see Alaka v. Att'y Gen., 456 F.3d 88, 106 (3d Cir.2006) (it was legal error for the IJ to consider the amount of intended loss for all of the charges rather than the single count for which she was convicted.); Nijhawan v. Holder, """ U.S. """", 129 S.Ct. 2294, 2303, 174 L.Ed.2d 22 (2009).