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we'll never know how many of the claimed 255 kills were real and how many of the real ones were innocent civilians.
As mentioned on a previous page, confirmation of a kill requires a third party, which is listed at like 160.
So we know for sure that he has at least that many.
I'd also like to add that from my experience in the military and having worked with snipers, they don't just kill indiscriminately and adhere to a strict set of ROE's. However, I never met Kyle and wasn't there holding his hand, so who knows.