1. Is evidence that establishes only the use of cellular telephones, the Internet or
hotels by a defendant, without any evidence of how the use of these means, facilities or
businesses were "in or affect[ed] interstate commerce," sufficient to find the interstate commerce
element for commercial sex trafficking under 18 U.S.C. § 1591(a)?

2. Does a Jury instruction that directs the jury that, "as a matter of law," the interstate
commerce element for commercial sex trafficking in 18 U.S.C. § 1591 (a) is met if the jury finds
beyond a reasonable doubt that the offense involved the use of cellular telephones, the Internet or
hotels constitute a conclusive presumption that violates a criminal defendant's right due process?

a. If such an instruction is erroneous in that it contains an unconstitutional
conclusive presumption, is that error obvious or plain as contemplated under the plain
error standard of review?

Is evidence that establishes only the use of cellular-telephones, internet, hotels sufficient to find the interstate-commerce element for commercial-sex-trafficking under 18-USC-1591(a)?