Opinion by Judge TASHIMA; Concurrence by Judge KLEINFELD.

The issue we resolve today is the viability of this circuit’s “invited error” doctrine following the Supreme Court’s decision in United States v. Olano, 507 U.S. 725 , 118 S.Ct. 1770 , 123 L.Ed.2d 508 (1993). The three-judge panel (“panel”) suggested that Olano overruled that doctrine, at least in the context of jury instructions specifically requested by the defendant. United States v. Perez, 67 F.3d 1371 , 1385 n. 13 (9th Cir.1995). On en banc review, we conclude that Olano limits our application of the invited error doctrine to those rights deemed waived, as opposed to merely forfeited, that is, “known right[s]” that have been “intentionally] relinquish[ed] or abandon[ed].” See Olano, 507 U.S. at 733 , 113 S.Ct. at 1777 (defining waiver).

In the case before us, we conclude that defendants-appellants Joseph E. Perez (“Perez”) 1 and John V. Cruz (“Cruz”) did not waive the proper jury instructions under 18 U.S.C. § 924 (c)(1), using or carrying a firearm in relation to drug trafficking. Even though both defendants submitted flawed instructions, neither they, the prosecution, nor the court apparently was aware of the correct law. Given these circumstances, the error cannot be deemed waived, but merely forfeited. We therefore undertake a plain error review. However, because we conclude that the error is not one that “seriously affeet[s] the fairness, integrity or public reputation of judicial proceedings,” id. at 736, 113 S.Ct. at 1779 (quoting United States v. Atkinson, 297 U.S. 157, 160 , 56 S.Ct. 391, *843 392 , 80 L.Ed. 555 (1936)), we do not “notice” the error under Federal Rule of Criminal Procedure 52(b). We therefore withdraw that portion of the original panel’s opinion concerning the flawed jury instructions under § 924(c)(1). Perez, 67 F.3d at 1384-86 . 2

I

FACTS AND PROCEDURAL BACKGROUND

This case arises out of a drug trafficking conspiracy in Guam. Defendants Cruz and Perez, along with others, were charged, and in some instances convicted, of various conspiracy, drug, and firearm counts. The following recitation of facts is pertinent to the convictions of Cruz and Perez under 18 U.S.C. § 924 (c)(1), using or carrying a firearm in relation to drug trafficking. 3

In 1992, Perez sold cocaine four times to a police informant. Guam police officers, in cooperation with federal agents, then put his residence under surveillance. The surveillance revealed that Perez exchanged firearms and other stolen goods for heroin from Cruz. According to a police informant, Perez discovered he was under surveillance, and cached the bulk of the contraband at Cruz’s residence. In December, 1993, the police obtained search warrants for the residences of both Cruz and Perez, and executed those warrants on December 28.

When officers entered Perez’s residence, he was seated on a couch with his girlfriend Matilda Paulino. As Perez stood up, officers saw a Caspian Arms .38 caliber pistol on the couch, which had been under Perez’s right leg. Police also found a .22 caliber pistol in Paulino’s purse, and a semi-automatic pistol in a bag in a hall.

In executing the search warrant of Cruz’s residence, undercover police knocked on his door and made an unsuccessful effort to draw Cruz out of his home. The officers then decided their cover had been blown, and so barged into the residence yelling “police officers!” Officers quickly discovered Cruz underneath the kitchen table, chambering a round into a loaded Glock-19 9 mm. pistol with a special laser sight. After his arrest, police also discovered a loaded SWD M-ll 9 mm. pistol and a Norinko SKS semi-automatic rifle in the master bedroom, and an Inter TEC-9 pistol with silencer in the living room.

Perez and Cruz, along with a third co-defendant, were tried together. 4 At trial, the prosecution introduced evidence connecting the guns found at the residences of Cruz and Perez to the respective defendants. Various witnesses also testified that Cruz and Perez sold heroin to friends while carrying a weapon. The prosecution adduced expert testimony that narcotic traffickers use weapons for protection and intimidation. The jury convicted both Cruz and Perez of distributing heroin in violation of 21 U.S.C. § 841 (a)(1), possessing heroin with intent to distribute in violation of 21 U.S.C. § 841 (a)(2), being felons in possession of firearms in violation of 18 U.S.C. § 922 (g)(1), and using or carrying firearms in relation to drug trafficking in violation of 18 U.S.C. § 924 (c)(1). 5 The indictment charged that Perez and Cruz possessed heroin with intent to distribute up to and including December 28, 1993. Thus, defendants were in the course of committing a drug trafficking crime on the date they were arrested with the weapons and in the circumstances described above.

II

DISCUSSION

Defendants contend their convictions under 18 U.S.C. § 924 (e)(1) should be over *844 turned because the trial court failed to instruct on an essential element of the crime. Section 924(c)(1) provides:

18 U.S.C. § 924 (c)(1) (emphasis added). In United States v. Mendoza, 11 F.3d 126 (9th Cir.1993), we held the statute’s “in relation to” requirement is an essential element of a § 924(c)(1) offense, which must be submitted to a jury. Id. at 128.

Although Mendoza was decided several months prior to defendants’ trial, the court did not submit the “in relation to” element to the jury. 6 A busy trial court cannot be blamed for this kind of error, particularly when both sides agreed that the flawed instruction, which was taken from the Manual of Model Criminal Jury Instructions for the Ninth Circuit, Instruction 819U (1992), should be given. Under these circumstances, we must now consider whether we may review the error and, if so, whether we should grant relief.

A. The Viability of the Invited Error Doctrine

We have held repeatedly that where the defendant himself proposes allegedly flawed jury instructions, we deny review under the invited error doctrine. See, e.g., United States v. Butler, 74 F.3d 916 , 918 n. 1 (9th Cir.1996); United States v. Staufer, 38 F.3d 1103 , 1109 n. 4 (9th Cir.1994); United States v. Baldwin, 987 F.2d 1432, 1437 (9th Cir.), cert. denied, 508 U.S. 967 , 113 S.Ct. 2948 , 124 L.Ed.2d 696 (1993); United States v. Guthrie, 931 F.2d 564, 567 (9th Cir.1991). The doctrine reflects the policy that invited errors “are less worthy of consideration than those where the defendant merely fails to object.” Guam v. Alvarez, 763 F.2d 1036, 1037 (9th Cir.1985). In the past, we have corrected invited errors only in extraordinary circumstances, such as “when the integrity of the judicial process itself would otherwise suffer.” Id. (quoting Marshall v. United States, 409 F.2d 925, 927 (9th Cir.1969)); but see, United States v. Freeman, 6 F.3d 586, 600 (9th Cir.1993) (conducting a plain error review of the omission of an entrapment instruction, even though the defendant had voluntarily withdrawn such an instruction at trial). The government argues that under our invited error doctrine, we may not review the error because Cruz and Perez both proposed the faulty instructions to the court.

By contrast, Cruz and Perez argue that we may review the error under Rule 52(b), which provides:

Fed.R.Crim.P. 52(b). Until now, we have undertaken a plain error review when the defendant merely failed to object to faulty instructions, as opposed to actually proposing or agreeing to faulty instructions. Baldwin, 987 F.2d at 1437 .

In Olano, the Court provides an extensive framework for plain error review. 507 U.S. at 731-87 , 113 S.Ct. at 1776-80 . Olano does not, however, specifically address the concept of invited error. From this omission, the panel concluded that plain error review is appropriate for invited errors:

*845 Perez, 67 F.3d at 1385 n. 13. Although Olano does not directly address so-called “invited error,” it certainly addresses the difference between forfeited and waived rights. 507 U.S. at 732-34 , 113 S.Ct. at 1776-78 . Accordingly, we cannot agree that Olano completely overruled our invited error doctrine. Instead, we must reformulate that doctrine to conform to Olano’s discussion of waiver and forfeiture.

Forfeiture is the failure to make a timely assertion of a right, whereas waiver is the “intentional relinquishment or abandonment of a known right.” Olano, 507 U.S. at 733 , 113 S.Ct. at 1777 (quoting Johnson v. Zerbst, 304 U.S. 458, 464 , 58 S.Ct. 1019, 1023 , 82 L.Ed. 1461 (1938)). Forfeited rights are reviewable for plain error, while waived rights are not. Id. “If a legal rule was violated during the District Court proceedings, and if the defendant did not waive the rule, then there has been an ‘error’ within the meaning of Rule 52(b) despite the absence of a timely objection.” Id. at 733-34, 113 S.Ct. at 1777 .

Until now, our invited error doctrine has focused solely on whether the defendant induced or caused the error. See Baldwin, 987 F.2d at 1437 (citing United States v. Montecalvo, 545 F.2d 684, 685 (9th Cir.1976), and Guthrie, 931 F.2d at 567 ). We now recognize, however, that we must also consider whether the defendant intentionally relinquished or abandoned a known right. Olano, 507 U.S. at 733 , 113 S.Ct. at 1777 . If the defendant has both invited the error, and relinquished a known right, then the error is waived and therefore unreviewable. 7

We do not mean to suggest that a defendant may have jury instructions reviewed for plain error merely by claiming he did not know the instructions were flawed. What we are concerned with is evidence in the record that the defendant was aware of, i.e., knew of, the relinquished or abandoned right. For example, in Baldwin , the defendant was charged' with conspiracy to distribute cocaine. 987 F.2d at 1436 . The court’s proposed instructions left out “overt act” as an element of the crime. Id. The government excepted to the instructions because they omitted this requirement. Id. at 1437 . The defendant’s attorney indicated that he did not believe it was necessary to instruct on the overt act requirement. Id. This scenario is an example of waiver because the record reflects that the defendant was aware of the omitted element and yet relinquished his right to have it submitted to the jury. 8 Accord Staufer, 38 F.3d at 1103 , 1109 n. 4 (waiver of error occurred because trial attorney modified model jury instructions to conform to most recent Supreme Court decision); Guthrie, 931 F.2d at 567 (refusal to review jury instructions under invited error doctrine, because trial court had offered to give omitted instruction, and defendant’s attorney objected). Waiver occurred in each of these cases because the defendant considered the controlling law, or omitted element, and, in spite of being aware of the applicable law, proposed or accepted a flawed instruction.

Here, however, the record reveals that neither defendants, the government, nor the court was aware of Mendoza’s requirement that the “in relation to” element be submitted to the jury. 11 F.3d at 128 . Although Cruz and Perez did submit erroneous instructions, there is no evidence that they affirmatively acted to relinquish a known right. That is, there is no evidence that Cruz and Perez considered submitting the “in relation to” element to the jury, but then, for some tactical or other reason, rejected the idea. Thus, it cannot be said that Cruz and Perez waived their right to have this *846 element submitted to the jury; waiver occurs only when a defendant relinquishes or abandons a “known right.” Olano, 607 U.S. at 733, 113 S.Ct. at 1777 .

To the contrary, the failure to propose the “in relation to” element was forfeited error: error that is not objected to during trial because the defendant is unaware of a right that is being violated. Here, because neither Cruz nor Perez knew of the right to have the omitted element submitted to the jury, we must treat the right as forfeited, as opposed to waived. Accordingly, we review the error under Rule 52(b) for plain error. See Johnson v. United States, - U.S.-,-, 117 S.Ct. 1544, 1548 , 137 L.Ed.2d 718 , - (1997) (forfeited right reviewed for plain error). 9

B. Plain Error Review

The Supreme Court mandated a four-part inquiry to determine whether an error may be corrected under Rule 52(b): (1) there must be error; (2) it must be plain; and (3) it must affect substantial rights. Olano, 507 U.S. at 732-35 , 113 S.Ct. at 1776-78 . Even after a reviewing court finds plain error under this three-part rubric, relief remains discretionary under Olano’s fourth and final requirement. Id. at 735-37 , 113 S.Ct. at 1778-80 . “The Court of Appeals should correct a plain forfeited error affecting substantial rights if the error ‘seriously affect[s] the fairness, integrity or public reputation of ju-dieial proceedings.’ ” Id. at 736 , 113 S.Ct. at 1779 (quoting Atkinson, 297 U.S. at 160 , 56 S.Ct. at 392 ). Applying this analytical framework to the case at bench, we conclude that, although there was error, and it was plain, it is not the kind of error that should be noticed under Olano’s final, discretionary prong. Accordingly, we do not grant relief.

1. Was There Error?

An error occurs when there has been a deviation from a legal rule, unless the rule has been waived. Olano, 507 U.S. at 732-33 , 113 S.Ct. at 1776-77 . Here, the alleged error is the district court’s failure to instruct on the “in relation to” element of § 924. Under Mendoza , the district court’s failure to submit this element to the jury was error. 11 F.3d at 128 . Moreover, as discussed in Part II.A, above, we conclude that neither Cruz nor Perez waived the error. Accordingly, there was “error.”

2. Was the Error Plain?

An error is plain when it is “clear” or “obvious” under the law. Olano, 507 U.S. at 734 , 113 S.Ct. at 1777-78 . Mendoza , which had been decided several months prior to defendants’ trial, clearly and unambiguously required the submission of the “in relation to” element to the jury. 11 F.3d at 128 . Accordingly, the error was “plain.” See also Johnson, - U.S. at-, 117 S.Ct. at 1549 (error not clear at time of trial, but *847 “ ‘plain’ at time of appellate consideration,” may qualify as “plain” error under Olano).

3.Did the Error Affect Substantial Rights?

In the context of plain error review, for an error to affect substantial rights, “in most cases it means that the error must have been prejudicial.” Olano, 507 U.S. at 734 , 113 S.Ct. at 1778 . “Normally, although perhaps not in every case, the defendant must make a specific showing of prejudice to satisfy the ‘affecting substantial rights’ prong, of Rule 52(b).” Id. at 735 , 113 S.Ct. at 1778 . Olano contains these cautionary statements (ie., “in most eases” and “normally”) in recognition of the fact that there the Court was dealing with a mere rule violation 10 and not a deprivation of a constitutional right. These statements suggest that there may be some cases, such as those involving the violation of certain constitutional rights, in which prejudice may not have to be shown.

Here, we are dealing with an asserted constitutional violation. Failure to submit an essential element to a jury relieves the prosecution of its obligation to prove every element beyond a reasonable doubt. Carella v. California, 491 U.S. 263, 265 , 109 S.Ct. 2419, 2420 , 105 L.Ed.2d 218 (1989) (citing In re Winship, 397 U.S. 358, 364 , 90 S.Ct. 1068, 1072-73 , 25 L.Ed.2d 368 (1970)). Depriving the jury of its fact-finding duty thereby violates a defendant’s due process right to have each element found beyond a reasonable doubt. Id. Failure to instruct on every element is, therefore, constitutional error. Id.

The error is not, however, presumptively prejudicial. See Roy v. Gomez, 81 F.3d 863, 866-67 (9th Cir.) (en banc) (concluding that omission of an essential element is not structural error and can be subjected to harmless error review), overruled on other grounds, - U.S. -, 117 S.Ct. 337 , 136 L.Ed.2d 266 (1996). “Even though an element of the offense is not specifically mentioned, it remains possible the jury made the necessary finding.” Id. at 867. Accordingly, we cannot presume that Cruz and Perez were prejudiced by the trial court’s error. 11 However, we need not make the difficult determination of whether it was prejudicial, or “whether the phrase ‘affecting substantial rights’ is always synonymous with ‘prejudicial.’ ” Olano, 507 U.S. at 735 , 113 S.Ct. at 1778 (citing Arizona v. Fulminante, 499 U.S. 279, 310 , 111 S.Ct. 1246, 1265 , 113 L.Ed.2d 302 (1991)). Instead, we follow the teaching of Johnson:

- U.S. at -, 117 S.Ct. at 1550. We, thus, assume that Cruz and Perez’s substantial rights were affected, that if Olano’s third prong requires a showing of prejudice, their rights were prejudiced, and proceed to Olano’s final requirement.

4. Does the Error “Seriously Affect the Fairness, Integrity or Public Reputation of Judicial Proceedings?”

In conducting our review of this element, “we consider all circumstances at trial including the strength of the evidence against the defendant.” United States v. Campbell, 42 F.3d 1199, 1204 (9th Cir.1994), cert. denied, 514 U.S. 1091 , 115 S.Ct. 1814 , 131 L.Ed.2d 738 (1995) (internal quotation omitted). See Johnson, - U.S. at-, 117 S.Ct. at 1550 (reviewing record under Ola-no’s fourth prong for strength of evidence in support of element omitted from instructions). The concern, of course, in failing to *848 submit the “in relation to” element to the jury is that a conviction may be based solely on evidence that a defendant committed a drug offense while merely possessing a firearm. United States v. Stewart, 779 F.2d 538, 539 (9th Cir.1985), overruled on other grounds by Bailey ¶. United States, — U.S. —, 116 S.Ct. 501 , 133 L.Ed.2d 472 (1995). 12 Thus, without the element, a jury may convict under § 924(c)(1) even if it finds that the weapons were not intended to facilitate the underlying drug crimes. The record before us, however, does not support that this occurred to either Cruz or Perez.

Police discovered Cruz chambering a round into a weapon under the kitchen table when they entered his home. Cruz was in the course of committing the charged drug trafficking crime, the possession of heroin with the intent to distribute, at that time. Perez had a gun lying under his leg while seated on a couch when police entered his home. Perez, likewise, was in the course of committing the charged drug trafficking crime at that time.

Moreover, police found various guns which were tied to the respective defendants at both defendants’ homes. Witnesses testified that the men carried guns while transacting drug deals. Finally, the prosecution offered expert testimony that drug dealers carry guns for protection and intimidation. 13

In short, there is strong and convincing evidence that Cruz and Perez carried and/or used the guns “in relation to” the charged drug transactions. All that is needed to meet this requirement is that “the gun at least must ‘faeilitat[e], or ha[ve] the potential for facilitating,’ the drug trafficking offense.” Smith v. United States, 508 U.S. 223, 238 , 113 S.Ct. 2050, 2059 , 124 L.Ed.2d 138 (1993) (quoting Stewart, 779 F.2d at 540 ) (emphasis added). It is therefore extremely unlikely that, if properly instructed, the jury would not have convicted Cruz and Perez of the § 924(c)(1) charge, i.e., it is highly likely that, on this record, it would have found that the weapons were intended to facilitate, or, at least, had “the potential for facilitating,” the on-going drug trafficking crime.

The Court’s recent comment in Johnson applies, as well, to-the case at bench:

- U.S. at-, 117 S.Ct. at 1550 (citations omitted). Accordingly, on this record, we conclude, under Olano’s final, discretionary prong, that this error does not warrant correction as “seriously affeet[ing] the fairness, integrity or public reputation of judicial proceedings.” Olano, 507 U.S. at 736 , 113 S.Ct. at 1779 .

Ill

CONCLUSION

Because Cruz and Perez did not waive the right to have the “in relation to” element submitted to the jury, we conclude that we should review the forfeited right under the plain error standard of Rule 52(b). However, after such review, we further conclude that, because the error does not “seriously affect the fairness, integrity or public reputation of judicial proceedings,” the error should not be noticed under Rule 52(b). We therefore withdraw that part of the original panel’s opinion concerning the jury instruction on using or carrying a firearm in relation to a drug trafficking crime, Perez, 67 F.3d at *849 1384-86 , and affirm the district court with respect to defendants’ assignment of error regarding omission of the “in relation to” element from the jury instructions under 18 U.S.C. § 924 (c)(1). •

Finally, we remand this case to the three-judge panel to determine whether the defendants’ convictions under 18 U.S.C. § 924 (c)(1) are affected by: (1) Bailey, - U.S.-, 116 S.Ct. 501 , 133 L.Ed.2d 472 , an issue the panel did not previously consider; or (2) the district court’s failure to submit a special verdict form regarding which firearm, or firearms, defendants used in connection with the drug trafficking offense.

. The panel opinion only addresses the flawed jury instructions under 18 U.S.C. § 924 (c)(1) in its discussion of Cruz's arguments on appeal. Perez filed a petition for rehearing, indicating that his conviction under § 924(c)(1) suffered from the same defect as Cruz's conviction. Perez also pointed out that he had joined in all of Cruz's arguments on appeal. Because we took this case en banc, the panel did not rule on Perez’s petition for rehearing. Given, however, that the issues are identical, we address Perez’s arguments on the merits together with those of Cruz.

. Although we took the entire case en banc, the only issue that concerns us is the jury instructions under 18 U.S.C. § 924 (c)(1). Perez, 67 F.3d at 1384-86 . The rest of the panel opinion is not affected by our en banc review, and is not withdrawn.

. The original panel opinion contains a more detailed recitation of the facts. Perez, 67 F.3d at 1374, 1377-78, 1381-82 .

. Louise Perez, the third co-defendant, was acquitted of conspiracy to use a firearm during drug trafficking, in violation of 18 U.S.C. §§ 371 and 924(c)(1). This opinion therefore does not concern her.

. The panel affirmed the convictions of Cruz and Perez under 21 U.S.C. §§ 841 (a)(1) & (2), and 18 U.S.C. § 922 (g). Perez, 67 F.3d at 1381, 1386 .

. The court gave the following instruction on 18 U.S.C. § 924 (c)(1):

. Not all rights are waivable. Olano, 507 U.S. at 733 , 113 S.Ct. at 1777 . “Whether a right is waivable; whether the defendant must participate personally in the waiver; whether certain procedures are required for waiver; and whether the defendant’s choice must be particularly informed or voluntary, all depend on the right at stake.” Id.

In this case, we need not conduct an extended analysis concerning the waivability of jury instructions. We have long held that jury instructions may be waived by a defendant's attorney. See, e.g., Staufer, 38 F.3d at 1109 n. 4 ("we deem [the jury instruction] issue waived”).

. Baldwin preceded United States v. Shabani, 513 U.S. 10 , 115 S.Ct. 382 , 130 L.Ed.2d 225 (1994), which overruled Ninth Circuit law that proof of an overt act was an element of a drug conspiracy under 21 U.S.C. § 846 .

. The concurring opinion contends that "our decision today is aberrant" because “[a]ll the other circuits to address invited error doctrine since Olano have held that it survives essentially unchanged.” The cases the concurrence relies on, however, do not support this proposition. In none of those cases did the court even consider whether Olano should inform the way the courts apply the invited error doctrine, let alone "hold” that the invited error doctrine "survives ... unchanged.” In fact, none of those cases even considered the issue we decide today-namely, whether the invited error doctrine should apply when a defendant has merely forfeited, rather than waived, a right. For example. United States v. Griffin, 84 F.3d 912, 924 (7th Cir.1996), applied the invited error doctrine, but only after explicitly finding that the defendant had waived his right to claim error. See also United States v. Ross, 77 F.3d 1525, 1542 (7th Cir.1996) (defendant "voluntarily waived any objection”); United States v. Mitchell, 85 F.3d 800, 808 (1st Cir.1996) (same); United States v. Balter, 91 F.3d 427, 434 (3d Cir.1996) (assuming waiver); United States v. Hardwell, 80 F.3d 1471, 1487 (10th Cir.1996) (finding waiver); United States v. Yu-Leung, 51 F.3d 1116, 1123 (2d Cir.1995) (same).

In United States v. Tandon, 111 F.3d 482 (6th Cir.1997), the court applied the invited error doctrine where the trial court gave the instruction sought by the defendant. While it is true that the court there did not expressly find waiver, there is no indication that the defendant was unaware of the right he relinquished. Id. at 489 . In short, none of these cases considered whether the invited error doctrine should be applied to a case involving forfeiture, rather than waiver. The concurrence's canvass of the other circuits omits United States v. Nelson, 102 F.3d 1344 (4th Cir.1996), which supports our position rather than that of the concurrence. There, the court applied plain error review to forfeited error. Id. at 1348 . Thus, our decision today is not "aberrant.”

. The error in Olano was the presence of alternate jurors during deliberation, in violation of Federal Rule of Criminal Procedure 24(c). 507 U.S. at 727 , 113 S.Ct. at 1774.

. The panel concluded that the omission of an essential element is a structural constitutional error, necessarily affecting "substantial rights.” Perez, 67 F.3d at 1385-86 . It relied on our holding in United States v. Gaudin that a court deciding materiality as a matter of law is a structural constitutional error. 28 F.3d 943, 951 (9th Cir.1994) (enbanc), aff'd, 515 U.S. 506 , 115 5. Ct. 2310, 132 L.Ed.2d 444 (1995). However, Roy , decided after the original panel opinion, clarified that, while it is structural error for a court to decide an element as a matter of law, it is not structural error for a court merely to omit an element from a jury's consideration. 81 F.3d at 866-67 .

. In United States v. Hernandez, 80 F.3d 1253, 1257 (9th Cir.1996), we held that Stewart had been overruled by Bailey to the extent it suggested that "the inert presence of a firearm, without more, is [ ] enough to trigger [the ‘use’ prong of] § 924(c)(1)" (quoting Bailey, - U.S. at -, 116 S.Ct. at 508 ). However, Stewart has not been overruled in any other respect. See United States v. Loaiza-Diaz, 96 F.3d 1335, 1336 (9th Cir.1996).

. While we do not suggest that the § 924(c)(1) offense could be based on the evidence summarized in this paragraph alone, it is, nonetheless, strong circumstantial, direct and expert evidence of defendants' modus operandi.