accountants, chemists, and demolition experts. Id. The background note adds that the guideline applies to those “who abuse ... their special skills” as “[s]uch persons generally are viewed as more culpable.” Id., comment, (backg’d). “If an average person off the street does not possess the skill, then the skill is considered special for the purposes of applying the enhancement.” De la Cruz Suarez, 601 F.3d at 1219 (quotation omitted). A special skill requires neither licensing nor formal education. United States v. Foster, 155 F.3d 1329, 1332 (11th Cir. 1998)(hold-ing that “[although printing does not require licensing or formal education, it is a unique technical skill that clearly requires special training”); see also United States v. Malgoza, 2 F.3d 1107, 1111 (11th Cir. 1993) (<HOLDING>). The district court did not clearly err in
holding lay persons performing tasks relating to real estate transactions were engaged in the unauthorized practice of law and explaining it is the duty of the court to protect the public from the activity of those who because of lack of professional skills may cause injury whether they are members of the bar or persons never qualified for or admitted to the bar quotation marks and citation omitted holding that it is not holding that court of appeals erred by holding in the first instance that members of a family are a particular social group without prior resolution of this issue by the bia holding that this court must remand to the bia to allow it to address in the first instance an issue that it has not yet considered holding that although not every instance of radio operation requires skills not possessed by members of the general public it is possible to develop expertise in that field that rises to the level of aspecial skill