COLJI-Crim. 5-1:20

The elements of the crime of trademark counterfeiting are:

1. That the defendant,

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

3. intentionally,

4. manufactured, displayed, advertised, distributed, offered for

sale, sold, or possessed with intent to sell or distribute,

5. marks, goods, or services,

6. that the defendant knew were, bore, or were identified by one

or more counterfeit marks, and

7. had possession, custody, or control of more than twenty-five

items bearing a counterfeit mark.

[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 trademark counterfeiting.

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 trademark counterfeiting.