Does the Attorney General have any basis to argue that a criminal street gang is not a criminal activity?

The Attorney General argues "a gang-related nexus finds no support in the language of the statute" and that People v. Ngoun "inadvertently suggested a new element . . . ." As he asserts, "Once a defendant is shown to be a member of [a criminal street] gang with primary activities defined by statute, there is no further requirement that the defendant promote those primary activities: rather, furthering, assisting or promoting any criminal conduct will suffice under the express language of the statute." (Italics omitted.) We disagree.