See United States v. Stobaugh, 420 F.3d 796, 803 (8th Cir.2005) ("While certified records are generally sufficient to prove prior convictions, they are not necessary.") (citation omitted); United States v. Chavaria-Angel, 323 F.3d 1172, 1176 (9th Cir. 2003) ("We . . . reject Defendant's invitation to create a per se or absolute rule requiring the use of certified records. We recognize that the use of certified records is an effective, efficient, and perhaps even preferable method of proving the circumstances underlying a prior conviction, but we find nothing in the statute, the case law, or logic that would require it."); see also United States v. Acosta, 287 F.3d 1034, 1038 (11th Cir.2002) (concluding that "[although the government could not produce a certified copy of the adjudication because Acosta's records were sealed," the government had proved his prior conviction beyond a reasonable doubt because "the uncertified copy the government did introduce was identical"); cf. United States v. Fordham, 187 F.3d 344, 347 (3d Cir.1999) ("To establish reliability of [a] foreign conviction, certified copies of the conviction albeit desirable are not required for the sentencing court's determination as to whether an upward adjustment is warranted."). We agree with these cases, including our unpublished decisions, and conclude that, although certainly preferable, certification is not a prerequisite to reliability.

Under § 4A1.2(h), foreign sentences do not count towards criminal history but may be considered under § 4A1.3. It seems reasonable, when considering the effect of foreign criminal conduct, to translate such conduct into guideline terms and thereby tie the departure to the structure of the guidelines. See United States v. Fordham, 187 F.3d 344, 348 (3d Cir. 1999) (affirming § 4A1.3 upward departure and noting what sentence for foreign conduct would have been under United States sentencing guidelines); see also United States v. Mundo, No. 99-4888, 2000 U.S. App. LEXIS 14451, at *4 (4th Cir. June 22, 2000) (affirming upward departure under § 4 A1.3 and noting that a conviction for the underlying, foreign conduct would have exposed the defendant to a sentence of up to five years imprisonment in the United States); United States v. Spencer, No. 94-10266, 1 995 U.S. App. LEXIS 2697, at *9-10 (9th Cir. Feb. 1, 1 995) (affirming upward departure to criminal history category defendant would have been in if he had been convicted of foreign crimes in the United States); cf. United States v. Korno, 986 F.2d 166, 168 (7th Cir. 1993) (rejecting defendant's contention that district court erred "by mechanically treating his Canadian convictions as the equivalent of domestic convictions and merely plugging the foreign convictions into the criminal history ca