that the holding in the case was essentially limited to a matter of statutory interpretation). However, since Archer, the Second Circuit has clarified that one variant of the manufactured jurisdiction doctrine is the claim that “the defendant’s due process rights were violated because the government’s actions in inducing the defendant to commit the federal crime were outrageous.” See Wallace, 85 F.3d at 1065-66 (citing United States v. LaPorta, 46 F.3d 152, 160 (2d Cir.1994)). In Wallace, the Second Circuit indicated that, for the due process variant of manufactured jurisdiction, the critical factors in the analysis are whether the government committed crimes, and harmed or lied to innocent third parties. See 85 F.3d at 1066; see also U.S. v. Tribble, 320 Fed.Appx. 85, 87 (2d Cir.2009) (<HOLDING>); LaPorta, 46 F.3d at 160. This reasoning is
holding that defendant staying in abandoned house had no legitimate expectation of privacy in the house despite having a key to the house and the ability to let people in and out of it holding that background social norms that invite a visitor to the front door do not invite him there to conduct a search holding an elaborate ruse to invite defendants to rob a fictitious stash house was not outrageous holding noknock entry justified where officers had reasonable suspicion that entering drug stash house would be dangerous and drug dealer frequenting house could not be found elsewhere holding that arrest by the back door of defendants house was unlawful