Whether the use of a name, without more, constitutes the use of a 'means of identification of another person' under 18 U.S.C. § 1028A

QUESTION PRESENTED The federal aggravated identity theft statute imposes an additional mandatory two-year prison sentence on anyone who “knowingly transfers, possesses, or uses, without lawful authority, a means of identification of another person” during and in relation to specified felony offenses. 18 U.S.C. § 1028A(a)(1). Under the statute, “means of identification” is defined as “any name or number that may be used, alone or in conjunction with any other information, to identify a specific individual.” Id. § 1028(d)(7) (emphasis added). There is an acknowledged conflict among the courts of appeals as to whether a defendant’s use of a person’s name—be it typed or the “use[]” of a “means of identification” under the aggravated identity theft statute. The question presented is: Whether the use of a name, without more, constitutes the use of a “means of identification of another person” under 18 U.S.C. § 1028A.