The Supreme Court held that to constitute a fraud aggravated felony, the loss to the victim resulting from the conviction must be tied or tethered to the specific count of conviction, rather than other offenses or dismissed counts. Nijhawan v. Holder, supra, 557 U.S. at 42 (the loss must be tied to the specific counts covered by the conviction. Brief for Respondent 44; see, e.g., Alaka v. Attorney General of United States, 456 F.3d 88, 107 (C.A.3 2006) (loss amount must be tethered to offense of conviction; amount cannot be based on acquitted or dismissed counts or general conduct); Knutsen v. Gonzales, 429 F.3d 733, 739"740 (C.A.7 2005) (same).). Moreover, the Ninth Circuit has previously held that where a plea agreement specifies a certain individual transaction, and the loss from that transaction does not exceed $10,000, the immigration authorities are limited to the loss specified in the plea agreement, even though total restitution in excess of $10,000 for the specific loss attributable to the count of conviction plus other relevant conduct and dismissed counts). Chang v. INS, 307 F.3d 1185 (9th Cir. 2002).