What is the legal test for finding that prosecutorial misconduct in addressing the jury warrants a new trial?

Defendants assert that prosecutorial misconduct in addressing the jury warrants a new trial.¹² To secure such relief, they must show misconduct "so severe and significant" as to deny a "fair trial." United States v. Coplan, 703 F.3d 46, 86 (2d Cir. 2012) (internal quotation marks omitted). Such cases are "rare," United States v. Caracappa, 614 F.3d 30, 41 (2d Cir. 2010), and arise only when improper comments so infect the trial as a whole as to result in conviction violative of due process, see United States v. Truman, 688 F.3d 129, 144 (2d Cir. 2012); United States v. Ferguson, 676 F.3d 260, 283 (2d Cir. 2011) (stating that improper comments do not deny due process "unless they constitute egregious misconduct" (internal quotation marks omitted)). In evaluating whether defendants have carried this burden, we consider (1) the severity of the misconduct, (2) the measures adopted to cure it, and (3) the certainty of conviction in the absence of the misconduct. See United States v. Coplan, 703 F.3d at 86. Applying

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