enhancement “when the combination of the defendant’s actions and words would instill in a reasonable person in the position of the immediate victim (e.g., a bank teller) a greater amount of fear than necessary to commit the robbery.” Id. (citing United States v. Robinson, 86 F.3d 1197, 1202 (D.C.Cir.1996) and United States v. Murray, 65 F.3d 1161, 1167 (4th Cir.1995)). Thus, the amendment of § 2B3.1 was designed to endorse the general, objective approach taken by the Ninth Circuit in France and to reject the “cramped” requirement of “direct” threats advanced by the Eleventh Circuit. See United States v. Day, 272 F.3d 216, 220 (3d Cir.2001). Accordingly, contra n” is a threat of death under the “broad[er]” amended enhancement); United States v. Franks, 183 F.3d 335, 338 (4th Cir.1999) (<HOLDING>); United States v. Soto-Martinez, 317 F.3d 477,
holding that the statement i have a gun is a threat of death because a reasonable teller upon hearing the statement normally and reasonably would fear that his or her life is in danger holding that a note stating i have a gun i have nothing to lose warrants the threatofdeath enhancement because a reasonable teller would have been in fear for her life holding that the statement i have a gun would cause a reasonable teller to fear being shot and that the phrase i am willing to use it would make a fear of death even more likely holding that i have a gun is sufficient to justify the sentencing enhancement because it merely requires a teller to make the reasonable inference that a robber would use the gun he claimed to have if he did not receive the money he demanded holding that i have a gun merits an enhancement because a reasonable teller would believe that failure to comply would result in being fatally shot