What is the government's burden of proving that each individual victim was a victim of the fraud?

The showing required to satisfy the government's burden on this point varies depending on the circumstances of the fraud. In some cases, it will be clear that no reasonable person would have given the defendant her money if she had known of his planas in the fraud in Ojeikere where the defendant's plan was to abscond with his co-conspirators' funds as soon as he got hold of their money. 545 F.3d at 223. See also United States v. Marino, 654 F.3d 310 (2d Cir.2011). In those cases, a generalized description of the fraudulent scheme is enough to support restitution. But where it is plausible that some individuals would have paid the defendant even if they had been informed of his fraudulent plan, then the government must proffer some individualized evidence to meet its burden of showing that each alleged victim was actually a victim. Cf. United States v. Gonzalez, 647 F.3d 41, 6567 (2d Cir.2011) (vacating a restitution award where the district court failed to calculate individualized and actual losses).