What is the test for establishing a primary activity of a criminal gang?

To establish the gang's primary activities, the trier of fact may look at past and present criminal activities of the gang. "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. Both past and present offenses have some tendency in reason to show the group's primary activity . . . ." (People v. Sengpadychith (2001) 26 Cal.4th 316, 323.)