In People v. Fuentes (2009) 171 Cal.App.4th 1133, the defendant was charged with murder, attempted murder, assault, street terrorism, and various other crimes involving the use of a firearm. (Id. at pp. 1136-1137.) Gang enhancements under Penal Code section 186.22, subdivision (b)(1) were alleged with respect to all charged crimes (except street terrorism). (Fuentes, supra, at pp. 1136-1137.) The trial court instructed the jury with CALCRIM No. 370, using the same language quoted ante. (Fuentes, supra, at p. 1139.) The defendant argued CALCRIM No. 370 contradicted the instruction for the gang enhancement allegations, which required the jury to determine whether the prosecution proved the defendant committed the crime for the benefit of, at the direction of, or in association with a criminal street gang, and that the defendant intended to assist, further, or promote criminal conduct by gang members. (Fuentes, supra, at p. 1139.) The appellate court stated: "An intent to further criminal gang activity is no more a 'motive' in legal terms than is any other specific intent. We do not call a premeditated murderer's intent to kill a 'motive,' though his action is motivated by a desire to cause the victim's death. Combined, the instructions here told the jury the prosecution must prove that the defendant intended to further gang activity but need not show what motivated his wish to do so. This was not ambiguous and there is no reason to think the jury could not understand it. The defendant claims the intent to further criminal gang activity should be deemed a motive, but he cites no authority for this position. There was no error. If the defendant's argument has a superficial attractiveness, it is because of the commonsense concept of a motive. Any reason for doing something can rightly be called a motive in common language, including--but not limited to--reasons that stand behind other reasons. For example, we could say that when A shot B, A was motivated by a wish to kill B, which in turn was motivated by a desire to receive an inheritance, which in turn was motivated by a plan to pay off a debt, which in turn was motivated by a plan to avoid the wrath of a creditor. That is why there is some plausibility in saying the intent to further gang activity is a motive for committing a murder: A wish to kill the victim was a reason for the shooting, and a wish to further gang activity stood behind that reason. The jury instructions given here, however, were well adapted to cope with the situation. By listing the various 'intents' the prosecution was required to prove (the intent to kill, the intent to further gang activity), while also saying the prosecution did not have to prove a motive, the instructions told the jury where to cut off the chain of reasons. This was done without saying anything that would confuse a reasonable juror." (Fuentes, supra, 171 Cal.App.4th at pp. 1139-1140.)