Does the "intangible rights" theory of fraud under section 1346 of the Criminal Code apply to private individuals as well as public figures?

deterrence and punishment of corruption among public officials, the courts have consistently recognized the statute's province to encompass dishonest acts perpetrated in private commercial settings"); United States v. deVegter, 198 F.3d 1324, 1330 (11th Cir.1999) (holding that the 1346 theory applies to private-sector defendants but that such cases must involve a breach of fiduciary duty and reasonably foreseeable economic harm); United States v. Sun-Diamond Growers of Cal., 138 F.3d 961, 973 (D.C.Cir.1998) (holding that the 1346 theory can support the conviction of a private defendant where "there [is] a failure to disclose something which in the knowledge or contemplation of the employee poses an independent business risk to the employer" (internal quotation marks and alteration omitted)). We follow our sister circuits and hold that the "intangible rights" theory of fraud, as codified by 1346, can apply to private individuals as well as to public figures.