1. The Defendant can be found guilty of that offense only if all of the following facts are proved beyond a reasonable doubt:
   1. That the Defendant transported or caused to be transported, or induced travel by, in interstate commerce, the person named in the indictment;
   2. That such travel was caused or induced by the Defendant in the execution or concealment of a scheme to defraud such person as charged in the indictment;
   3. That the Defendant knew the scheme was fraudulent and acted with intent to defraud; and
   4. That the purpose of the scheme to defraud was to obtain money or property from such person having value of $5,000 or more.

The “value” of something means the face, par or market value, or cost price, either wholesale or retail, whichever is greater.

The term “interstate commerce” includes any movement or transportation of a person or persons from one state into another state, the District of Columbia, or any commonwealth, territory, or possession of the United States.

The word “scheme” includes any plan or course of action intended to deceive other, and to obtain, by false or fraudulent pretenses, representations or promises, money or property from persons so deceived.

A statement or representation is “false” or “fraudulent” if it relates to a material fact and is known to be untrue or is made with reckless indifference as to its truth or falsity, and is made or caused to be made with intent to defraud. A statement or representation may also be “false” or “fraudulent” when it constitutes a half-truth or effectively conceals a material fact, with intent to defraud. A “material fact” is a fact that would be important to a reasonable person in deciding whether or not to engage in a particular transaction.

To act with “intent to defraud” means to act knowingly and with the specific intent to deceive someone, ordinarily for the purpose of causing some financial loss to another or bringing about some financial gain to one’s self.