Is simple possession a lesser-included offence?

Appellants argue that the evidence in this case compelled the trial court to give a lesser-included offense instruction for simple possession. A lesser-included offense instruction is required only where a disputed factual element is present in the greater but not the lesser charge. Sansone v. United States, 380 U.S. 343, 350, 85 S.Ct. 1004, 13 L.Ed.2d 882 (1965). Appellants argue that the fact that the government introduced only circumstantial evidence made the element of intent to distribute disputed.