COLJI-Crim. 3-3:18

The elements of the crime of internet luring of a child are:

1. That the defendant,

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

3. knowingly,

4. communicated by computer or computer network, telephone

network, data network, text message or instant message,

5. to a person whom the defendant knew or believed to be under

fifteen years of age and,

6. in that communication, or in any subsequent communication

by computer, computer network, telephone network, data

network, text message, or instant message,

7. described explicit sexual conduct, and

8. in connection with that description, made a statement

persuading or inviting the person to meet the defendant for any

purpose, and

9. the defendant was more than four years older than the person

or the age the defendant believed the person to be.

[10. 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 internet luring of a child.

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 internet luring of a child.