What is the test for establishing that a Defendant is a member of a criminal gang?

"We discuss those arguments that are sufficiently developed to be cognizable. To the extent defendant perfunctorily asserts other claims, without development and, indeed, without a clear indication that they are intended to be discrete contentions, they are not properly made, and are rejected on that basis. [Citations.]" (People v. Freeman (1994) 8 Cal.4th 450, 482, fn. 2.) We thus do not discuss any issue relating to evidence of defendant's gang membership or any other contention that has not been clearly articulated.