Whether the Government is required to show that drug activity constitutes the primary or principal purpose of the property, or only that drug distribution was a significant purpose

QUESTIONS PRESENTED 21 U.S.C. § 856 (A)(2) makes it unlawful to manage or control any place, whether permanently or temporarily, either as an owner, lessee, agent, employe, occupant, or mortgagee, and knowingly and intentionally rent, lease profit from, or make available for use, with or without compensation, the place for the purpose of unlawfully manufacturing, storing, distributing, or using a controlled substance. To establish the element of “purpose” is the Government required to show that the drug ) activity constitutes either the primary or principal purpose of the property as some circuits have held (The Ninth, Tenth), or is the Government required to show only that drug distribution was a significant purpose as other circuits have held (The Third, The Fifth, The Sixth Circuits)? ii