The following excerpt is from United States v. Pristell, 941 F.3d 44 (2nd Cir. 2019):
In addition to the role requirement, the criminal activity must involve five or more participants or be otherwise extensive. A "participant" is defined as "a person who is criminally responsible for the commission of the offense, but need not have been convicted." U.S.S.G. 3B1.1 cmt. n. 1. "In assessing whether an organization is 'otherwise extensive,' all persons involved during the course of the entire offense are to be considered," including the defendant himself. Id. at cmt. 1 n. 3. Thus, a crime that "involved only three participants but used the unknowing services of many outsiders could be considered extensive." U.S.S.G. 3B1.1 cmt. n. 3. While a district court's findings should be sufficient to permit meaningful appellate review, courts "should be given latitude concerning their supervisory role findings, even when their findings were not as precise as they might have been." United States v. Napoli , 179 F.3d 1, 14 (2d Cir. 1999) (internal quotation marks omitted).
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