9th Cir. Model Jury Instr. (Criminal) 23.14

The defendant is charged in [Count_____ of] the indictment with economic espionage in

violation of Section 1831 of Title 18 of the United States Code. For the defendant to be found guilty of that charge, the government must prove each of the following elements beyond a reasonable doubt:

First, the defendant [intended] [knew] that his actions would benefit any [foreign government] [foreign instrumentality] [foreign agent];

Second, the defendant knowingly:

[[stole] [without authorization [appropriated] [took] [carried away] [concealed]] [obtained by fraud] [obtained by artifice] [obtained by deception] a trade secret];

or

[without authorization [copied] [duplicated] [sketched] [drew] [photographed] [downloaded] [uploaded] [altered] [destroyed] [photocopied] [replicated] [transmitted] [delivered] [sent] [mailed] [communicated] [conveyed] a trade secret];

or

[[received] [bought] [possessed] a trade secret, knowing the same to have been [stolen] [appropriated without authorization] [obtained without authorization] [converted without authorization]].