The following excerpt is from U.S. v. Korab, 893 F.2d 212 (9th Cir. 1989):
To convict for aiding and abetting a criminal offense, the evidence must establish that the offense actually was committed. United States v. Powell, 806 F.2d 1421, 1424 (9th Cir.1986). An individual is guilty of federal extortion if "with intent to extort from any person, firm, association, or corporation, any money or other thing of value, [he] transmits in interstate commerce any communication containing any threat ... to injure the person of another shall be fined or imprisoned ... or both." 18 U.S.C. Sec. 875(b) (emphasis added). The transmittal of a threat in interstate commerce is an integral element of federal extortion. States are presumably competent to prosecute extortion fully contained within the state.
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