COLJI-Crim. 20:13

The elements of the crime of gaming fraud (use of knowledge) are:

1. That the defendant,

2. in the State of Colorado, at or about the date and place charged,

[3. placed, increased, or decreased a bet or determined the course

of play,

4. after acquiring knowledge, not available to all players, of the

outcome of the game or any event that affected the outcome of

the game or which was the subject of the bet.]

[3. aided anyone in acquiring knowledge, not available to all

players, of the outcome of a game or any event that affected the

outcome of the game or which was the subject of a bet,

4. for the purpose of placing, increasing, or decreasing a bet or

determining the course of play contingent upon that event or

outcome.]

[5. and that the defendant’s conduct was not legally authorized by

the affirmative defense[s] in Instruction[s] ___.]

After considering all the evidence, if you decide the prosecution has

proven each of the elements beyond a reasonable doubt, you should find

the defendant guilty of gaming fraud (use of knowledge).

After considering all the evidence, if you decide the prosecution has

failed to prove any one or more of the elements beyond a reasonable doubt,

you should find the defendant not guilty of gaming fraud (use of

knowledge).