specify just one means alone. 12 . The Seventh Circuit has subsequently held that § 2422(b) criminalizes persuasion (and an attempt to persuade) rather than the underlying sexual activity. United States v. Berg, 640 F.3d 239, 250-51 (7th Cir. 2011) ("Because Berg was charged with a § 2422(b) attempt, the government’s burden was to prove beyond a reasonable doubt that he intended to persuade, induce, or entice someone whom he believed was a minor to engage in sexual activity—not that he intended to engage in sexual activity.”). Berg did not mention the earlier Mannava decision. 13 . Obviously, if a defendant has successfully persuaded a minor to engage in an unlawful sexual act, this will typically mean that the act was completed and the likelihood of multiple potential s . App. 1990) (<HOLDING>); Hutcherson v. State, 441 So.2d 1048, 1052
holding that firstdegree sexual abuse is a lesserincluded offense of firstdegree rape holding that the trial court erred by refusing to instruct the jury on seconddegree sexual abuse which is a lesserincluded offense of firstdegree rape holding that that the trial court erred when it determined that firstdegree sexual offense was an aggravated offense holding that conspiracy to commit murder is not lesserincluded offense of firstdegree murder holding that fetus was not a human being for purposes of attempted firstdegree intentional homicide and firstdegree reckless injury statutes