What is the test for establishing a "primary activities" in a criminal gang?

(2) one of the group's primary activities must be the commission of one of the specified predicate offenses; and (3) the group's members must 'engage in or have engaged in a pattern of criminal gang activity.'" (People v. Loeun (1997) 17 Cal.4th 1, 8 (Loeun).)² Defendant challenges the sufficiency of the evidence with regard to the "primary activities" element.

"Evidence of past or present conduct by gang members involving the commission of one or more of the statutorily enumerated crimes is relevant in determining the group's primary activities." (People v. Sengpadychith (2001) 26 Cal.4th 316, 323.) "Sufficient proof of the gang's primary activities might consist of evidence that the group's members consistently and repeatedly have committed criminal activity listed in the gang statute." (Id. at p. 324.)