How have the courts treated the issue of "street terrorism" in the context of a disputed supplemental jury instruction?

^7. On June 17, 2016, the day after the trial court provided its disputed supplemental instruction, the jury sent a written note asking if the court could "clear up" the charge in count 3 (street terrorism). The jury stated it needed "clarification on active participation and the promotion of gangs." The court responded, "I am limited to the jury instructions defining those issues." In his reply brief, appellant contends the trial court should have elaborated further on the elements of street terrorism, which "compounded" the court's alleged error regarding the disputed supplemental jury instruction. We will not address appellant's assertion the court should have elaborated further on the elements of street terrorism because that claim was not raised in appellant's opening brief. (See People v. Rangel (2016) 62 Cal.4th 1192, 1218-1219.)