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United States v. Watson, 966 F.2d 161, 163 (5th Cir.1992); United States v. Russell, 913 F.2d 1288, 1292-93 (8th Cir.1990). These circuits held that the retail value was the appropriate measure of value because the use of the wholesale value "would only encourage disparate sentencing for essentially similar criminal acts," particularly in those.

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See Ovalles v. United States, 861 F.3d 1257, 1265-66 (11th Cir. 2017) ("The required ‘nexus’ between the 924(c) firearm offense and the predicate crime of violence makes the crime of violence determination more precise and more predictable."). But this firearm requirement simply means that the statute will apply

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