The following excerpt is from U.S. v. Coyne, 4 F.3d 100 (2nd Cir. 1993):
We have recently held, in a case involving these very transactions, that Section 666 covers payments for both past acts--a gratuity theory--and payments related to future acts--a bribery theory, see United States v. Crozier, 987 F.2d 893, 898-99 (2d Cir.1993) (holding Section 666 should be construed to include gratuities). The evidence described in the preceding paragraph is more than sufficient with regard to either theory.
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