USA Today carefully notes that 104 American troops have been "killed by enemy fire" in Iraq since the President declared the end of major combat on May 1. During the war between March to May, 110 troops were "killed in action."
"Action" sounds more vague than "enemy fire." According to the Dept. of Defense dictionary, "killed in action" is a "casualty category applicable to a hostile casualty" excluding terrorism. So the postwar numbers may be quite higher. If the Defense department itself is using these categories, I hope reporters are noticing the switch.
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