What is the current state of the law in relation to Kann?

^2.Kann involved alleged violations of the mail fraud statute. Since mail and wire fraud are both defined as any scheme or artifice to defraud, or for obtaining money or property by means of false or fraudulent pretenses, representations, or promises, 18 U.S.C. 1341, 1343, the wire fraud statute is read in light of the case law on mail fraud, United States v. Manarite, 44 F.3d 1407, 1411 n. 5 (9th Cir.1995); accord Carpenter v. United States, 484 U.S. 19, 25 n. 6, 108 S.Ct. 316, 98 L.Ed.2d 275 (1987) (applying the same analysis to mail and wire fraud).