In this task, you will be shown a prompt from a judicial decision and multiple holding statements derived from citations following text in a legal decision.  Holdings represent the governing legal rule when the law is applied to a particular set of facts. There are five answer choices for each citing text. The correct answer is the holding statement that corresponds to the citing text. You should write an incorrect option. Even though there exist multiple wrong answers, we only need a single wrong answer. There is a <HOLDING> token in the position of the citing text prompt where the holding statement was extracted.

Q: method (under § 3663) in favor of an incorrect method (under § 1593), the district court erred. Moreover, we hold that the district court’s error was “plain,” because the statutes are clear and because the government openly admitted that its proposed methodology derived from the wrong restitution statute. See United States v. Tuyet Thi-Bach Nguyen, 565 F.3d 668, 677 (9th Cir.2009) (“An error is plain when it is ‘clear’ or ‘obvious’ under the law.”). Finally, we hold that the error affected Defendants’ substantial rights and affected the fairness, integrity, or public reputation of the judicial proceedings. The government did not present evidence — and the district court did not make findings — of the victims’ actual losses, as required by § 3663. See Bussell, 504 F.3d at 964 (<HOLDING>); United States v. Joyner, 201 F.3d 61, 81 (2d 
 Holding statements: (A) holding that restitution is proper under  2259 only to the extent the defendants offense proximately caused a victims losses (B) holding that restitution is proper for victims losses that are directly caused by appellants conduct for which he was convicted (C) holding that under the restitution provision of the supervised release statute 18 usc  3583 restitution can be ordered only for losses caused by the specific conduct that is the basis for the offense of conviction (D) holding that the amount of restitution is limited to the victims actual losses  (E) holding that restitution in the full amount of each victims losses does not exceed the statutory maximum

A: holding that restitution is proper under  2259 only to the extent the defendants offense proximately caused a victims losses
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Q: to pay the purchase price. 3.Pursuant to the Securities Purchase Agreement, dated September 2, 2004, Mer-vyn's Holdings purchased 100% of the interests in Holdings I and Holdings II for $429,746,414,84. At the closing, Mervyn’s Holdings used these funds to pay the purchase price. (Am.Compl.$ 58). 5 . Brandt v. Trivest II, Inc. (In re Plassein Int’l Corp.), 352 B.R. 36, (Bankr.D.Del.2006) ("Accordingly, the Court joins with those decisions that have (either implicitly or explicitly) evaluated fraudulent transfer complaints using Rule 8(a)(2)’s notice pleading standard”) Id. at 40-41. See. e.g., Giuliano v. U.S. Nursing Corp. (In re Lexington Healthcare Group, Inc.), 339 B.R. 570, 574-75 (Bankr.D.Del.2006) (applying "liberal notice pleading standard”); AstroPower, 335 B.R. at 333 (<HOLDING>); Official Comm, of Unsecured Creditors v. DVI 
 Holding statements: (A) holding despite collective allegations in complaint the complaint was not deficient under rule 8a because it stated with sufficient particularity facts establishing a causal connection between the defendants actions and the constitutional deprivation (B) holding that a fraudulent transfer complaint need only set forth the facts with sufficient particularity to apprise the defendant fairly of the charges made against him (C) holding that the fraud claims against the defendant should not have been dismissed as the complaint provided him with fair notice of the claims made against her (D) holding that the information must set forth each element of the crime that it charges as well as fairly inform a defendant of the charge against which he must defend (E) holding that a criminal defendant is entitled to know the charges against him and to be tried solely upon the charges against him internal quotation marks and citation omitted

A: holding despite collective allegations in complaint the complaint was not deficient under rule 8a because it stated with sufficient particularity facts establishing a causal connection between the defendants actions and the constitutional deprivation
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Q: Garcia’s argument stumbles at the starting gate because he does not explain how Rule 23 conflicts with the “more lenient” standard he proposes under Massachusetts law. Garcia suggests that Rule 23 might interfere with his substantive right to proceed as a class. But he does not explain how a class certification analysis under Massachusetts law would proceed any differently from a Rule 23 analysis. See United States v. Zannino, 895 F.2d 1, 17 (1st Cir.1990) (“It is not enough merely to mention a possible argument in the most skeletal way, leaving the court to do counsel’s work, create the ossature for the argument, and put flesh on its bones.”). Nor do the cases cited by Garcia shed any light on what a “more lenient” standard would look like here. See Machado, 989 N.E.2d at 470 (<HOLDING>); Sebago v. Tutunjian, 85 Mass. App.Ct. 1119, 7 
 Holding statements: (A) holding that the federal arbitration act requires piecemeal resolution when necessary to give effect to an arbitration agreement and mandates enforcement of an arbitration agreement notwithstanding the presence of other persons who are parties to the underlying dispute but not to the arbitration agreement emphasis added (B) holding that the federal arbitration act requires enforcement of class action waivers in arbitration clauses even when massachusetts law provides for a substantive right to bring a class proceeding (C) holding that the district court did not err by compelling individual rather than class arbitration because the relevant agreements were silent as to class arbitration (D) holding that rookerfeldman precludes jurisdiction over a federal lawsuit to compel arbitration under the federal arbitration act because the action was inextricably intertwined with the plaintiffs failed statelaw action to compel arbitration under the louisiana arbitration act (E) holding that an aaa arbitration was a private proceeding and therefore that a decision by the arbitrator pursuant to the federal arbitration act did not constitute state action

A:
holding that the federal arbitration act requires piecemeal resolution when necessary to give effect to an arbitration agreement and mandates enforcement of an arbitration agreement notwithstanding the presence of other persons who are parties to the underlying dispute but not to the arbitration agreement emphasis added
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