Footnote 233

See United States v. 6.45 Acres of Land (Gettysburg Tower), 409 F.3d 139, 146 & n.13 (3d Cir. 2005) (“[W]e have applied the unit rule as the legal procedure by which just compensation is to be determined and apportioned.”); United States v. 1.377 Acres of Land (Hotel San Diego), 352 F.3d 1259, 1269 (9th Cir. 2003) (government provides just compensation, then respective interest holders apportion award).