COLJI-Crim. 3-4:47

The elements of the crime of internet sexual exploitation of a child

(observe) are:

1. That the defendant,

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

3. knowingly,

4. importuned, invited, or enticed,

5. through communication via a computer network or system,

telephone network, data network, text message, or instant

message,

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

fifteen years of age, and at least four years younger than the

defendant,

7. to observe the defendant’s intimate parts via a computer

network or system, telephone network, data network, text

message, or instant message.

[8. 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 sexual exploitation of a child (observe).

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 sexual exploitation of a

child (observe).