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Ne Case 1:20-cr-00330-PAE Document565- Filed 12/19/21 Page 23 of 83 Instruction No. 16: Count Two: Enticement to Engage in Illegal Sexual Activity — Second Element The second element of Count Two which the Government must prove beyond a reasonable doubt is that the individual traveled in interstate commerce, as alleged in the Indictment. As I just stated, “interstate commerce” simply means movement between one state and another. ae DOJ-OGR-00008729