What is the test for "specific intent" to promote, further, or assist in any criminal conduct by gang members?

The second prong requires "the specific intent to promote, further, or assist in any criminal conduct by gang members." ( 186.22, subd. (b)(4).) "Intent is rarely susceptible of direct proof and usually must be inferred from the facts and circumstances surrounding the offense." (People v. Pre (2004) 117 Cal.App.4th 413, 420.) Here, appellant's numerous gang-related tattoos "advertis[ed]" that he was committing the crimes for the benefit of a criminal street gang. Appellant thrust his head into the car, and both victims saw appellant's tattoos. Both victims recognized from the tattoos that appellant was a Pacas gang

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member. From this evidence the jury could reasonably infer that appellant's crimes promoted and furthered criminal conduct by Pacas gang members. Thus, the evidence was sufficient to satisfy the specific intent prong. (See People v. Morales (2003) 112 Cal.App.4th 1176, 1198 ["specific intent" element means "'specific intent to promote, further, or assist in any criminal conduct by gang members . . .'"].)