What is the test for determining whether there was a single conspiracy encompassing multiple counts?

that defendant either actively participated in or instigated every crime committed by the PimpStyle Hustlers. Whether the jurors concluded there was single conspiracy encompassing multiple counts or that each count constituted a separate conspiracy, the result would have been the same. There is no reasonable probability of a more favorable verdict had the jury been explicitly instructed that it was to determine the number of conspiracies. (People v. Watson (1956) 46 Cal.2d 818, 836, 299 P.2d 243.)¹⁹

[61 Cal.4th 1272]

Finally, defendant contends [t]he jury should have been instructed to agree unanimously whether there was a single or multiple conspiracies. We have previously rejected that argument when a count of conspiracy has not been charged but the doctrine is merely relied upon as a theory of culpability for the crimes for which the defendant is on trial. (People v. Valdez (2012) 55 Cal.4th 82, 153154, 144 Cal.Rptr.3d 865, 281 P.3d 924 ; People v. Prieto (2003) 30 Cal.4th 226, 251, 133 Cal.Rptr.2d 18, 66 P.3d 1123.)