district
court did not plainly err in counting the merchants' losses.

Departures are reviewed under the test set out in Koon v. United
States, 518 U.S. 81, 96-100 (1996). A criminal history category which
inadequately reflects the defendant's past criminal conduct is an
encouraged factor for departure. See USSG§ 4A1.3. Murphy objects
to the extent of the departure, which we review for abuse of discre-
tion, see United States v. Gary, 18 F.3d 1123, 1130 (4th Cir. 1994),
and to the court's method of structuring the departure. The district
court noted that category VI accounted for only 15 of Murphy's 63
criminal history points. The court removed two minor offenses from
consideration and determined that 44 criminal history points
remained. The court divided that number by three (the number of
criminal history points in most criminal history categories), for a
result ofEgyptian newspaper under fire over altered photo Published duration 15 September 2010

image caption President Mubarak leads the way in the altered al-Ahram image

Egypt's state-run newspaper has come under fire for altering a photograph to suggest President Hosni Mubarak was leading the Middle East peace talks.

Al-Ahram showed Mr Mubarak walking on a red carpet ahead of US President Barack Obama as well as the Israeli, Palestinian and Jordanian leaders.

The original image, taken at the White House when talks were formally re-launched, shows Mr Obama leading the way and Mr Mubarak trailing behind.

image caption The original image from the White House, taken on 1 September

Talks resumed in Egypt on Tuesday.

The manipulated photograph ran above an article on page six of al-Ahram's Tuesday edition, entitled The Way to Sharm el-Sheikh.

US Secretary