Campbell

MEMORANDUM **

Defendant John Campbell (“Campbell”), convicted by a jury of charges arising out of a scheme masterminded by his co-defendants in which the participants used fraudulently obtained credit to purchase computer merchandise from wholesale computer companies and resold the merchandise at a profit without repaying the credit extended to them, appeals his 48-month sentence on the grounds that the district court wrongly: (1) applied a two-point Guidelines enhancement for use of sophisticated means; (2) rejected a two-point Guidelines reduction for acceptance of responsibility; and (3) imposed a harsher sentence than that ultimately received by his more culpable co-defendants, who were sentenced to prison terms of 21 months and 41 months, respectively.

The district court did not err in applying a two-point enhancement for use of sophisticated means. This enhancement applies whenever “the offense ... involved sophisticated means,” U.S. Sentencing Guidelines Manual § 2Bl.l(b)(9)(C) (emphasis added), and the Sentencing Commission has clarified that “offense” in this context refers to “the overall offense conduct for which the defendant is accountable,” not “the personal…