What is the burden of proving improper comment in summation?

A defendant seeking to overturn a conviction based on an improper comment in summation bears the "heavy burden" of showing that "the comment, when viewed against the entire argument to the jury, and in the context of the entire trial, was so severe and significant as to have substantially prejudiced him, depriving him of a fair trial." United States v. Farhane, 634 F.3d 127, 167 (2d Cir. 2011) (citations and internal quotation marks omitted). In assessing whether a defendant has been substantially prejudiced, we consider "the severity of the misconduct, the curative measures taken, and the certainty of

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conviction absent the misconduct." United States v. Rosa, 17 F.3d 1531, 1549 (2d Cir. 1994).