BILL ANALYSIS                                                                                                                                                                                                    Ó



          SENATE COMMITTEE ON PUBLIC SAFETY
                             Senator Loni Hancock, Chair
                                2015 - 2016  Regular 

          Bill No:    AB 160        Hearing Date:    June 30, 2015     
          
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          |Author:    |Dababneh                                             |
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          |Version:   |May 5, 2015                                          |
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          |Urgency:   |No                     |Fiscal:    |Yes              |
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          |Consultant:|JM                                                   |
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           Subject:  Criminal Profiteering: Counterfeit Labels:  Sales and  
 
                                      Use Taxes



          HISTORY

          Source:   Jerome Horton, Chairman of the Board of Equalization

          Prior Legislation:AB 2681 (Dababneh) - Ch. 477, Stats. 2014
                         AB 90 (Swanson) - Ch. 457 Stats. 2011
                         AB 924 (Emmerson) - Ch. 111, Stats. 2007 
                         AB 988 (Bogh) - Ch. 53, Stats. 2005
                         SB 968 (Bowen) - Ch. 125, Stats. 2004
                         AB 1990 (Liu) - Ch. 991, Stats. 2002
                         AB 662 (Wesson) - 1999, vetoed

          Support:  Association of Federal State County and Municipal  
                    Employees; California Chamber of Commerce; California  
                    District Attorneys Association; California College and  
                    University Police Chiefs; California Police Chiefs  
                    Association; California Retailers Association  
                    California State Sheriffs' Association; California  
                    Statewide Law Enforcement Coalition; California State  
                    Lodge; Fraternal Order of Police; Independent  
                    Insurance Agents and Brokers of California; Liberty  
                    Mutual Insurance; Long Beach Police Officers  
                    Association; Los Angeles Area Chamber of Commerce; Los  








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                    Angeles County Professional Peace Officers  
                    Association; Motion Picture Association of America,  
                    Inc.; Sacramento County Deputy Sheriffs' Association;  
                    Valley Industry and Commerce Association

          Opposition:None known

          Assembly Floor Vote:                 77 - 0


          PURPOSE

          The purpose of this bill is to 1) add piracy of musical or  
          audiovisual works, and unemployment insurance fraud to the list  
          of crimes for which criminal asset forfeiture is authorized; 2)  
          expand the definition of "organized crime" for purposes of  
          criminal asset forfeiture to include pimping and pandering,  
          loan-sharking, trademark counterfeiting, the piracy of a  
          recording or audiovisual work, embezzlement, securities fraud,  
          unemployment insurance fraud, grand theft, money laundering, and  
          forgery;  3) define a "retail sale" or "sale at retail" to  
          include any sale by a convicted seller of tangible personal  
          property with a counterfeit label or an illicit label; 4)  
          provide that "storage" and "use" include a purchase by a  
          convicted purchaser of tangible personal property with a  
          counterfeit label or an illicit label; and 5) define  
          "counterfeit label" and "illicit label" as those terms are  
          defined in federal law - a label that appears to be genuine but  
          is not, and a genuine label that a person uses without  
          authorization respectively.
          
          Existing law:

          Includes the criminal profiteering asset forfeiture law, which  
          applies where the defendant is convicted of a specified offense  
          and the defendant has engaged in a pattern of criminal  
          profiteering activity, as specified.  (Pen. Code § 186.3.)  The  
          following assets or property are subject to forfeiture:

                 Any property interest whether tangible or intangible,  
               acquired through a pattern of criminal profiteering  
               activity.
                 All proceeds of a pattern of criminal profiteering  
               activity, which property shall include all things of value  









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               that may have been received in exchange for the proceeds  
               immediately derived from the pattern of criminal  
               profiteering activity.

          Existing law states that forfeited cash and proceeds of the sale  
          of forfeited property shall be distributed as follows: 

                 To the bona fide or innocent purchaser, conditional  
               sales vendor, or holder of a valid lien, mortgage, or  
               security interest, up to the amount of his or her interest  
               in the property or proceeds, as specified.
                 To the Department of General Services or local  
               governmental entity for all expenditures incurred in  
               connection with the sale of the forfeited property.
                 To the State General Fund or the general fund of the  
               local governmental entity, whichever prosecutes.  (Pen.  
               Code § 186.8), except in the child pornography or recycling  
               fraud cases.
                 In a case of fraud involving the state recycling  
               program, to a special fund designated in the Public  
               Resources Code.
                 In the case of child pornography crimes, to the county  
               children's trust fund or State Children's Trust Fund.
                 In a case involving human trafficking of minors for  
               purposes of prostitution or lewd conduct, or a case of  
               procurement of a minor, to the Victim-Witness Assistance  
               Fund for child sexual exploitation and abuse counseling and  
               prevention programs.  Fifty percent of the funds shall be  
               granted to community-based organizations that serve minor  
               victims of human trafficking.

          Existing law states that any person who willfully manufactures,  
          intentionally sells, or knowingly possesses for sale any  
          counterfeit of a mark registered with the California Secretary  
          of State or registered on the United States Patent and Trademark  
          Office shall be punishable as follows:

                 If the offense involves less than 1,000 of the  
               articles with a total retail value less than the  
               standard for grand theft (over $400 - $487), the  
               defendant is guilty of a misdemeanor, punishable by  
               a fine of not more than $5000, imprisonment in a  
               county jail for up to one year, or by both.  If the  
               defendant is a corporation, by a fine of not more  









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               than $100,000.

                 When the crime involves 1,000 or more articles,  
               or has a total retail value that meets the standard  
               for grand theft (over $400 - $487), the crime is an  
               alternate felony-misdemeanor, punishable by  
               imprisonment in a county jail for up to one year, or  
               in the state prison for 16 months, 2 years or 3  
               years, by a fine not to exceed $250,000, or both.   
               If the defendant is a corporation, the maximum fine  
               is $500,000.  (Pen. Code § 350, subd. (a).)

          Existing law provides that a repeated violation of the  
          counterfeit trademark statute is an alternate  
          felony-misdemeanor, punishable by a fine of not more than  
          $50,000, imprisonment in a county jail for not more than one  
          year, or in the state prison for 16 months, or 2 or 3 years, or  
          both.  If the defendant is a corporation, the maximum fine is  
          $200,000.  (Pen. Code § 350, subd. (b).)


          Existing law provides that where a defendant is convicted of a  
          trademark counterfeiting, the court shall order the forfeiture  
          and destruction of all of counterfeit marks and all counterfeit  
          items.  The court, with specified exceptions for community  
          property vehicles, shall also order forfeiture and destruction  
          or other disposition of all means of making the marks, and all  
          other devices for making or transporting the marks used in  
          connection with the violation.  

          Existing law describes "fair use" of a trademark, which is not  
          subject to prosecution or a civil action, as any of the  
          following:

                 advertising or promotion that permits consumers to  
               compare goods or services;
                 identifying and parodying, criticizing, or commenting  
               upon the famous mark owner or the goods or services of the  
               famous mark owner;
                 noncommercial use of the mark; and
                 all forms of news reporting and news commentary.  (Bus.  
               & Prof. Code § 14247.)
           
           Existing federal law provides that it is a crime to "traffic" or  









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          "attempt to traffic" in counterfeit goods.  The crime is  
          punishable by a fine of up to $2,000,000, imprisonment for up to  
          10 years, or both.  The maximum fine for a corporation or an  
          entity other than an individual is $5,000,000.  Repeated  
          convictions are punishable by imprisonment for up to 20 years, a  
          fine of up to $5,000,000, or both.  Where the convicted  
          defendant of repeated violations is other than an individual the  
          maximum fine is $15,000,000.  (18 U.S.C. § 2320.)

          Existing federal law provides the following property is subject  
          to forfeiture following a defendant's conviction for trafficking  
          in counterfeit goods:  the proceeds of the crime; any of the  
          defendant's property used or intended to be used in the crime;  
          any article bearing a counterfeit mark.  (18 U.S.C. § 2320 (b).)

          This bill:

          Expands the list of offenses that can serve as a basis for  
          criminal profiteering asset forfeiture - employed against  
          organized crime - to include piracy of audio or audiovisual  
          works and unemployment insurance fraud.   

          Expands provisions from the "organized crime" element as it  
          pertains to criminal profiteering by the provisions that require  
          that the nature of the conspiratorial action be of an organized  
          nature to include such examples as: 

                 pimping and pandering;
                 counterfeiting of any registered trademark; 
                 illegal piracy of recordings or audiovisual works; 
                 embezzlement;
                 securities fraud;
                 state tax fraud;
                 unemployment insurance fraud;
                 grand theft;
                 money laundering; and
                 forgery.

          Adds, to the definition of a "retail sale" or "sale at retail,"  
          the sale of tangible personal property (TPP) with a counterfeit  
          or illicit label regardless of whether the sale is for resale in  
          the regular course of business.

          Adds, to the definition of "storage" or "use," a purchase by a  









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          convicted purchaser of TPP in connection with a counterfeit  
          label or illicit label, regardless of whether the purchase is  
          for resale in the regular course of business. 

          Defines "counterfeit label" as having the same meaning as United  
          States Code (USC), Title 18, Section 2318 - a label that appears  
          to be genuine, but is not.

          Defines "illicit label" as having the same meaning as USC, Title  
          18, Section 2318 - a genuine label that is used without  
          authorization.

                    RECEIVERSHIP/OVERCROWDING CRISIS AGGRAVATION

          For the past eight years, this Committee has scrutinized  
          legislation referred to its jurisdiction for any potential  
          impact on prison overcrowding.  Mindful of the United States  
          Supreme Court ruling and federal court orders relating to the  
          state's ability to provide a constitutional level of health care  
          to its inmate population and the related issue of prison  
          overcrowding, this Committee has applied its "ROCA" policy as a  
          content-neutral, provisional measure necessary to ensure that  
          the Legislature does not erode progress in reducing prison  
          overcrowding.   

          On February 10, 2014, the federal court ordered California to  
          reduce its in-state adult institution population to 137.5% of  
          design capacity by February 28, 2016, as follows:   

                 143% of design bed capacity by June 30, 2014;
                 141.5% of design bed capacity by February 28, 2015; and,
                 137.5% of design bed capacity by February 28, 2016. 

          In February of this year the administration reported that as "of  
          February 11, 2015, 112,993 inmates were housed in the State's 34  
          adult institutions, which amounts to 136.6% of design bed  
          capacity, and 8,828 inmates were housed in out-of-state  
          facilities.  This current population is now below the  
          court-ordered reduction to 137.5% of design bed capacity."(  
          Defendants' February 2015 Status Report In Response To February  
          10, 2014 Order, 2:90-cv-00520 KJM DAD PC, 3-Judge Court, Coleman  
          v. Brown, Plata v. Brown (fn. omitted).

          While significant gains have been made in reducing the prison  









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          population, the state now must stabilize these advances and  
          demonstrate to the federal court that California has in place  
          the "durable solution" to prison overcrowding "consistently  
          demanded" by the court.  (Opinion Re: Order Granting in Part and  
          Denying in Part Defendants' Request For Extension of December  
          31, 2013 Deadline, NO. 2:90-cv-0520 LKK DAD (PC), 3-Judge Court,  
          Coleman v. Brown, Plata v. Brown (2-10-14).  The Committee's  
          consideration of bills that may impact the prison population  
          therefore will be informed by the following questions:

              Whether a proposal erodes a measure which has contributed  
               to reducing the prison population;
              Whether a proposal addresses a major area of public safety  
               or criminal activity for which there is no other  
               reasonable, appropriate remedy;
              Whether a proposal addresses a crime which is directly  
               dangerous to the physical safety of others for which there  
               is no other reasonably appropriate sanction; 
              Whether a proposal corrects a constitutional problem or  
               legislative drafting error; and
              Whether a proposal proposes penalties which are  
               proportionate, and cannot be achieved through any other  
               reasonably appropriate remedy.


          COMMENTS

          
          1.Need for This Bill

          According to the author:

               The problem with current Penal Code section 186.2 is  
               that it is internally inconsistent.  The list of 33  
               crimes set forth in subd. (a) to which the statute is  
               supposed to apply, does not mesh with the additional  
               requirements found in subd. (d), i.e., that it also be  
               "organized crime."  "Organized crime" is defined in  
               such a way in subdivision (d) (by listing 12 other  
               types of illegal activity), that it is hard to match  
               it up with one of the 33 enumerated crimes the statute  
               was intended to address. 

               Additionally, the list of crimes addressed in Penal  









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               Code 186.2 is deficient; it does not take into account  
               all of the crimes that make up the underground  
               economy.  Indeed, after over a year of investigation  
               and testimony, the Little Hoover Commission released  
               on March 9, 2015, a report about underground economy  
               crimes (tax evasion, counterfeiting, worker's comp  
               fraud, etc.) and listed as one of its recommendations  
               that "The state should refine and expand its asset  
               seizure laws to improve the collection of victim  
               restitution."  (Lit. Hov. Comm. Report, #226, p. x.)   
               The report specifically mentions AB 160 in this  
               regard. 

          2.The Basics of Criminal Asset Forfeiture
          
          History:  In 1982, the California Legislature passed the  
          California Control of Profits of Organized Crime Act.  The  
          express purpose of the Act was to punish the activities of  
          organized crime through the forfeiture of profits acquired and  
          accumulated as a result of engaging in a pattern of criminal  
          profiteering activity.  All property gained through that  
          activity is subject to forfeiture.  (Penal Code §§ 186 and  
          186.1.)

          Procedure:  Criminal profiteering asset forfeiture is a criminal  
          proceeding held in conjunction with the trial of the underlying  
          criminal offense.  Often, the same jury that heard the criminal  
          charges determines whether the defendant's assets were the  
          ill-gotten gains of criminal profiteering.  As a practical  
          matter, the prosecution must assemble its evidence for the  
          forfeiture matter simultaneously with the evidence of the crime.

          Proceeds:  Under existing law the forfeited proceeds of criminal  
          profiteering are placed in the county general fund with no  
          directions for use.  There are limited exceptions. For example,  
          forfeiture in child pornography cases is deposited in the county  
          or State Children's Trust Fund for child abuse and neglect  
          prevention and intervention.  (Pen. Code § 186.8; Welf. Inst.  
          Code §§ 18966 and 18969.)

          Contrast with Drug Asset Forfeiture:  In contrast to criminal  
          asset forfeiture, drug asset forfeiture is a separate civil  
          action.  With limited exceptions, a conviction for an underlying  
          drug offense is required.  However, the prosecution in drug  









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          asset forfeiture can conduct substantial civil discovery to find  
          the defendant's assets.  Law enforcement receives 65% of drug  
          forfeiture proceeds.  Federal forfeiture law authorizes a  
          federal agency to "adopt" a state seizure and return as much as  
          80% of the proceeds to the state or local agency.  The United  
          States Attorney General has recently limited adoption of state  
          forfeitures.  SB 443 (Mitchell) would rewrite the California  
          drug asset forfeiture law.  Most notably, SB 443 would prohibit  
          state or local law enforcement agencies from transferring seized  
          property to a federal agency for adoption, require that property  
          seized pursuant to federal law be distributed to state and local  
          law enforcements according to state law formulas, and that  
          convictions be obtained before the agencies could share in  
          federal forfeiture proceeds.   
          
          3.Expansion of the Control of Profits of Organized Crime Act -  
            Criminal Asset Forfeiture 
           
           It was the intent of the Legislature, when enacting the criminal  
          asset forfeiture law, to punish and deter criminal activities of  
          organized crime through the forfeiture of profits acquired and  
          accumulated as a result of such criminal activities.  Criminal  
          asset forfeiture is allowed upon conviction of more than 30  
          crimes, including extortion, pimping and pandering, robbery,  
          grand theft, trafficking in controlled substance, money  
          laundering, and offenses related to counterfeiting.  Proceeds  
          can be forfeited if the proceeds were gained through a pattern  
          of criminal activity and were gained through involvement in  
          organized crime.  This bill adds offenses related to music and  
          video piracy and unemployment insurance fraud to the list of  
          "criminal profiteering activity." The bill also matches the  
          definition of "organized crime" - to the list of specific crimes  
          for which criminal asset forfeiture is authorized.  That is, the  
          bill essentially what members of criminal organizations do match  
          what how criminal organizations are defined.  

          4.The Underground Economy
          
          The underground economy is a well-documented problem in the  
          State of California.  The Board of Equalization (BOE) has  
          estimated that $8 billion in corporate, personal, and sales and  
          use tax (SUT) revenues go uncollected in California each year,  
          with unreported and underreported economic activity responsible  
          for the vast majority of that total, placing a burden on state  









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          and local governments, and legitimate businesses; tackling the  
          problem has not been easy.  In 1993, the Joint Enforcement  
          Strike Force was created to combat the underground economy by  
          aiding in the sharing of information, coordinating enforcement  
          efforts, and developing methods to target enforcement resources.  
           Additionally, the Labor Task Force has also been launched in an  
          effort to curb the underground economy.  Through its information  
          sharing program, the Labor Task Force attempts to ensure that  
          employees receive proper payments and that California receives  
          all employment taxes and fees owed

          5.Sales and Use Tax on Counterfeit Items

          AB 2681 (Dababneh), Chapter 477, Statutes of 2014, expanded the  
          definition of "retail sale" or "sale at retail" to include any  
          sale by a convicted seller of TPP with a counterfeit mark  
          regardless of whether the sale is for resale in the regular  
          course of business.  This bill again expands the definition to  
          further include "counterfeit label" and "illicit label."

          It is unclear if imposing a tax on counterfeit items, regardless  
          of whether the sale is for resale in the regular course of  
          business, would discourage criminals from selling counterfeit  
          items.  Like most business models, a seller of counterfeit goods  
          makes a profit if sales revenues exceed costs.  However, unlike  
          legitimate businesses, sellers of counterfeit goods must  
          additionally take into account the potential costs of government  
          prosecution and civil lawsuits from genuine producers.  These  
          considerations may have a huge impact on a seller's decision to  
          carry counterfeit items, especially if the government has  
          improved enforcement of trademark laws or increased sentences.   
          The more active the government becomes in enforcing laws, the  
          more likely sellers will choose not to carry counterfeit  
          products.  The threat of sales tax, on its face, may be seen as  
          one additional tool to deter a person from selling counterfeit  
          items because it increases the costs of doing business.   
          However, the collection of sales tax is secondary to the threat  
          of being caught.  Thus, a person selling counterfeit goods would  
          not likely be deterred by the possibility of having to remit  
          sales tax, especially when the imposition of the tax is only  
          imposed after a conviction.
           
           However, there are well-known cases where organized criminals  
          were prosecuted for tax fraud when prosecutors had difficulty  









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          proving the crimes from which the organizations derived income  
          that was not reported.  The most notable and well-known case is  
                                    the conviction of Al Capone for tax fraud.<1>  Tax fraud charges  
          could also be used in plea bargaining.     
          


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