Kotteakos v. United States, 328 U.S. 750, 66 S. Ct. 1239, 90 L. Ed. 1557 (1946), illustrates a situation in which the nature of the fraud renders lack of knowledge of other participants legally significant. In Kotteakos, a single loan broker, a man named Simon Brown, attempted through fraudulent representations to obtain separate loans for thirty-two separate individuals. The common connection among the thirty-two individuals was that each had dealt with Brown. Some of the individuals had referred some of the other individuals to Brown. Everyone knew Brown was a broker who was willing to obtain fraudulent loans. The question was whether the evidence showed one vast conspiracy comprising of Brown and the thirty-two individuals, or a number of smaller conspiracies. The Court firmly held that the evidence established the existence of a number of smaller conspiracies, rather than one vast conspiracy. Id. at 770, 66 S. Ct. at 1250, 90 L. Ed. at 1569.