Does the invited response doctrine apply in the context of the reasonable doubt standard?

⁴ The dissent argues that defense counsel's discussion of the reasonable doubt standard invited the prosecutor's comment during rebuttal argument. But the invited response doctrine is not implicated here because the prosecutor's initial improper statements preceded defense counsel's argument. See United States v. Weatherspoon , 410 F.3d 1142, 1150 (9th Cir. 2005). Perhaps for that reason, the government elected not to raise such an argument in its answering brief. Nonetheless, "even if any defense statements were somehow viewed as opening the door to a prosecutorial response," the prosecutor's comment "would still be inappropriate because the prosecution is not allowed to use improper tactics even in response to similar tactics by the defense. " Id. (quoting United States v. Sarkisian , 197 F.3d 966, 990 (9th Cir. 1999) ). "Prosecutors must understand the differentand specialplace that they occupy in the criminal justice system," which, "as representative of the United States[,] ... demands the exercise of far better restraint and better judgment than was exhibited here." Id.