Smokin' the key in the Donovan OSS case IMO is:
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within the borders of their country in order to undermine or overthrow a constituted government or civil authority.
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Donovan was not operating within the borders of his own country. He was conducting unconventional warfare, in all its definitions, in support of conventional warfare against a foreign enemy. Now, if the Nazis has occupied the US and did it, then yes. Other than that, I can't really explain it. You can count him if you want, but I don't.
goat
I just wanted to see if you knew your history. I would count him among the greats for what he achieved in the Philippines and one of the great counter-insurgents for his work in SEA.