U.S. Brown

Dist. Ct. did not err in sentencing defendant to 240-month term of incarceration on possession and transportation of child pornography charges even though Dist. Ct. applied five-level enhancement under section 2G2.2(b)(3)(B) of USSG for distribution of child pornography for receipt of thing of value, but not for pecuniary gain. Ct. rejected defendant's argument that said enhancement constituted impermissible double-counting where, according to defendant, thing of value was image underlying instant possession conviction, since instant enhancement was based on aggravating features of defendant's conduct and not on elements of offenses for which he was convicted.