For example, in the case against businessman Frederic Bourke, Judge Shira Scheindlin instructed the jury that a "facility in interstate or foreign commerce" could include anything that crosses state or national borders, including telecommunications, and that conviction under the Travel Act requires proof that the defendant used a facility of commerce "for the purpose of facilitating the unlawful activity" but that the underlying offense (in Bourke's case, bribery of a foreign official) need not have been actually completed. Likewise, courts have applied the Travel Act to commercial bribery overseas in cases where state law prohibited such activities. One example of this was the case against Control Components, Inc. (CCI), a California corporation, which stood accused of violating both the FCPA and the Travel Act by bribing government officials and employees of private companies. California Penal Code Section 641.3 prohibits commercial bribery. When the company's lawyers challenged the extraterritorial application of the Travel Act, U.S. District Judge James V. Selna held that all elements of the Travel Act violation had been completed within California and that the offense "was complete the moment Defendants used a channel of foreign commerce allegedly to offer a 'corrupt payment' to an employee and thereafter effectuated a payment to that employee." At least one commentator has noted that Travel Act violations could be used as predicate acts under the Racketeer Influenced and Corrupt Organizations Act, since it is mentioned in the definition of "racketeering activity" in . International Travel Act of 1961 amendments for American tourism and international trade with the United States.