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The bias is not the "counting" but the context.

You have to compare the death rate with the rate of murder/genocide committed under Saddam, which it is not.

Then you have to break down the casualties into "direct death" i.e. "civilians" who are actually combantatns, into accidental deaths (e.g. shooting a car that doesn't stop because the innocent driver got scared and stepped on the gas instead of the break, so all the passengers were killed by soldiers), then counting the accidental deaths (shooting to crowds where terrorists ran) and accidental (from explosions ).

Then you have to count those killed deliberately by the "insurgents" i.e. in car bombs, or who were deliberately killed, or whose entire families were killed in revenge. Then you have to count those killed by thugs in the anarchy, e.g. kidnapping for money or robbery.

Until you break it down, giving pure "numbers" are anti American propaganda...