16 the other was the more expansive global federal part of the NPA. Third, as every circuit recognizes (including the Second and Seventh), it is a well- settled proposition that ambiguities in a plea agreement are to be resolved against the government. See, e.g., In re Altro, 180 F.3d 372, 375 (2d Cir. 1999); United States v. Carmichael, 216 F.3d 224 (2d Cir. 2000) (“[Wle ‘construe plea agreements strictly against the Government.”) (inter- nal citation omitted); United States v. O'Doherty, 64 F.3d 209, 217 (7th Cir. 2011); United States v. Transfiguracion, 442 F.3d 1222, 1229 (9th Cir. 2006). Annabi, Thompson, and the opinion below flip this guidepost on its head, holding that a promise of immunity from prosecution by “the United States” is to be construed against the defendant. 771 F.2d at 672; 431 Fed. Appx. 492 (App.8). If it is not in fact clear on its face that the United States means the United States as a whole, at most the intent in using this term is ambiguous. Because such ambiguity is to be resolved in favor of the defendant and against the government, 180 F.3d at 375, the majority interpretation that the United States refers to the country as a whole is correct and the opinion below must be reversed. C. The available evidence suggests that the NPA was meant to bind the Southern District of New York. Despite the Second Circuit’s conclusion below that the text and the negotiating history of this NPA suggest an intent to bind only the Southern District of Florida, (App.10), the opposite is true. First, the contractual interpretation principle known as expressio unius est exclusio alterius compels the DOJ-OGR-00000058