The following excerpt is from U.S. v. Koenig, 952 F.2d 267 (9th Cir. 1991):
We have held that the Act permits restitution "only for losses directly resulting from the defendant's offense." United States v. Kenney, 789 F.2d 783, 784 (9th Cir.) (internal quotations omitted), cert. denied, 479 U.S. 990, 107 S.Ct. 586, 93 L.Ed.2d 588 (1986). For example, there we held that a restitution award to a "bank to pay salaries of employees who testified at trial is not warranted because it was too remote to form the basis for restitution." Id. (internal quotations omitted). The conspirators argue that our cases compel a holding that the district judge erred by ordering restitution for the expenses incurred by the bank in notifying customers of the theft, answering customer inquiries and reprogramming stolen accounts.
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