What is the test for establishing the jurisdiction of a criminal offence in two or more jurisdictions?

When an "offense is committed in part in one jurisdictional territory and in part in another, or the acts or effects thereof constituting or requisite to the consummation of the offense occur in two or more jurisdictional territories, the jurisdiction of such offense is in any competent court within either jurisdictional territory."¹³ ( 781.) Section 781 is construed "liberally in order to achieve its underlying purpose, which is to expand venue beyond the single county in which a crime may be said to have been committed." The phrase "acts or effects ... requisite to the consummation" of a crime does not require that those acts amount to an element of the crime. (People v. Price (1991) 1 Cal.4th 324, 385, 3 Cal.Rptr.2d 106, 821 P.2d 610.) These words encompass preparatory acts. (People v. Posey, supra, 32 Cal.4th at p. 219, 8 Cal.Rptr.3d 551, 82 P.3d 755 [telephone call made to county of venue for purpose of planning crime was sufficient preparatory act]; Price, supra, 1 Cal.4th at pp. 384-386, 3 Cal.Rptr.2d 106, 821 P.2d 610 [theft of firearms in county of venue, leading to murder in another, was sufficient preparatory act].) The prosecution must prove the facts establishing venue by a preponderance of the evidence. (See People v. Cavanaugh, supra, 44 Cal.2d at p. 262, 282 P.2d 53; People v. Carter (1935) 10 Cal.App.2d 387, 52 P.2d 294.)