Prosecutors have used these laws widely to cover the full range of frauds as well as blackmail, counterfeiting, and other crimes. The laws have also served as stopgap devices to permit the prosecution of new kinds of fraud until Congress enacts laws to cope with them. The three elements of a mail fraud are: (1) a scheme to defraud, (2) the intent to defraud, and (3) the use of the United States mails or a private interstate commercial carrier to further that scheme. The wire fraud law further requires that the communication cross State lines. The two defenses to alleged violations are the good-faith defense and the statute of limitations. The action that establishes venue must relate to the use of the mails or wires. Penalties include fines, prison terms, or both. The Federal Sentencing Guidelines cover sentences in the provisions titled "Offenses Involving Fraud and Deceit." Each mailing can constitute a separate count of mail fraud. Footnotes