interests by avoiding defense theories that could have exposed ClearOne to criminal liability. To support her claim, Ms. Flood cites the government’s allegation at sentencing that Clear-One had been involved in the fraud and was therefore ineligible for restitution. Id. at 3873. However, Ms. Flood has not identified a viable, alternative strategy. See Bowie, 892 F.2d at 1500; see also Noe v. United States, 601 F.3d 784, 790-91 (8th Cir.2010) (rejecting conflict of interest claim where defendant had “not shown that [alternative strategies] were objectively reasonable”). Moreover, she has not shown that SCM relinquished that strategy “for the benefit of another party.” Alvarez, 137 F.3d at 1252 (quotation omitted); see United States v. Carpenter, 769 F.2d 258, 263 (5th Cir.1985) (<HOLDING>). Without more, the conflict is “purely
holding that under the eaja a litigant did not incur fees when his former employer agreed to pay his legal fees and expenses holding that plaintiff failed to adequately brief an issue where he failed to cite any legal authority for the proposition holding that a party had failed to preserve an argument for appellate review when that party had failed to argue the issue to the trial court either at trial or in his postjudgment motion holding that defendant is entitled to qualified immunity because plaintiff failed to allege the violation of a clearly established constitutional right holding that defendant failed to allege any strategy which defense counsel used or failed to use because a third party had agreed to pay the legal fees