Does an indictment charging the offense of wire fraud require pleading and proof of a specific false statement or omission, or is the allegation of an unspecified 'material scheme to defraud' sufficient?

QUESTION PRESENTED The wire fraud statute criminalizes the use of wire communications to effect “any scheme or artifice to defraud, or for obtaining money or property by false or fraudulent pretenses, representations, or promises.” 18 U.S.C. § 1343. In Neder v. United States, 527 U.S. 1, 25 (2000), this Court held that materiality of the falsehood is an element of the federal mail fraud, wire fraud, and bank fraud statutes. Despite this holding, the Ninth Circuit Court of Appeals continues to hold, as it did in the present case, that it is unnecessary to allege specific false statements or omissions when setting forth the crime of wire fraud. The question presented is: Does an indictment charging the offense of wire fraud, in violation of 18 U.S.C. § 1348, require pleading and proof of a specific false statement or omission, or is the allegation of an unspecified “material scheme to defraud” sufficient to state all elements of the offense?