The statute does not define the phrase "obtained by fraud." Fraud is defined by nontechnical standards and is not to be restricted by any common-law definition of false pretenses. One court has observed, "[t]he law does not define fraud; it needs no definition; it is as old as falsehood and as versatile as human ingenuity." Weiss v. United States, 122 F.2d 675, 681 (5th Cir. 1941), cert. denied, 314 U.S. 687 (1941). The Fourth Circuit, reviewing a conviction under 18 U.S.C. § 2314, also noted that "fraud is a broad term, which includes false representations, dishonesty and deceit." See United States v. Grainger, 701 F.2d 308, 311 (4th Cir. 1983), cert. denied, 461 U.S. 947 (1983).
[cited in JM 9-46.100]