The following excerpt is from U.S. v. Robinson, 46 F.3d 1148 (9th Cir. 1994):
The trial court need not exhaustively determine the pecuniary losses and quantify the risks of each potential victim of the fraudulent scheme. It need only use "a realistic, economic approach to determining what losses [West Coast] caused or intended to cause." United States v. Harper, 32 F.3d 1387, 1392 (9th Cir. 1994). The district court's estimate -- funds received by West Coast under the guise of providing truckers with liability and cargo insurance -- is reasonable. Its estimate of loss is approximately one-half the fair market value of the insurance purportedly provided.
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