The following excerpt is from U.S. v. Guadagna, 183 F.3d 122 (2nd Cir. 1999):
However, direct proof of defendant's fraudulent intent is not necessary. Intent may be proven through circumstantial evidence, including by showing that defendant made misrepresentations to the victim(s) with knowledge that the statements were false. United States v. Smith, 133 F.3d 737, 743 (10th Cir. 1997).
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