In People v. Orellano (2000) 79 Cal. App. 4th 179 [93 Cal. Rptr. 2d 866], Division Four of the Second Appellate District concluded there was a reasonable likelihood that former CALJIC No. 2.50.01 and CALJIC No. 2.50.1 misled jurors to believe they could infer the defendant's guilt merely from his commission of a prior offense, established by a preponderance of the evidence. The Orellano court held the error reversible, despite the giving of standard reasonable doubt instructions, because "we have no way of knowing whether the jury applied the correct burden of proof." (Orellano, at p. 186.) In People v. Vichroy (1999) 76 Cal. App. 4th 92 [90 Cal. Rptr. 2d 105], Division Two of the Second District held that even when the jury was instructed to determine beyond a reasonable doubt whether the defendant committed the prior offenses, it was reversible error to permit the jury to convict the defendant based solely on a finding that he had committed prior sexual offenses. (Id. at pp. 99-101.) On the other hand, the Fifth District has decided that, when the challenged instructions were considered together with those on reasonable doubt and the elements of the charged offense, juries were not reasonably likely to return a conviction based on an unconstitutionally lenient standard of proof or on evidence of uncharged offenses alone; hence, no error arose from the use of former CALJIC No. 2.50.01 and CALJIC No. 2.50.1. (People v. Van Winkle (1999) 75 Cal. App. 4th 133, 147-149 [89 Cal. Rptr. 2d 28]; People v. O'Neal (2000) 78 Cal. App. 4th 1065, 1078-1079 [93 Cal. Rptr. 2d 248].) The same reasoning has been adopted by the Fourth District, Divisions Two (People v. Waples (2000) 79 Cal. App. 4th 1389 [95 Cal. Rptr. 2d 45]) and Three (People v. Regalado (2000) 78 Cal. App. 4th 1056 [93 Cal. Rptr. 2d 83].) The Regalado court suggested that, even if the instructions were erroneous, the error could be found harmless in view of the strength of the evidence against the defendant. (Regalado, at pp. 1063-1064, fn. 5.)