What is the test for a jury to convict a defendant on charges of mail or wire fraud?

In order to convict on charges of mail or wire fraud, a jury must find proof beyond a reasonable doubt of fraudulent intent, meaning "that the defendant had a conscious, knowing intent to defraud . . . and that the defendant contemplated or intended some harm to the property rights of the victim." United States v. Guadagna, 183 F.3d 122, 129 (2d Cir. 1999) (internal quotation marks and brackets omitted). Proof of fraudulent intent may be established through circumstantial evidence. Id.