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separately Melton, writing for Sears) who argue that “issue” means giving the document to the “ultimate user.” Majority: “Because this provision broadly includes possession of the document by any “person other than the person whose signature appears thereon,” it is completely inconsistent with exclusion of a person who is a staff member, regardless of whether she is intended to be the ultimate user herself or is instead expected to complete the document in the future at the direction of the licensed physician who employs her.” “Furthermore, subsection (h) neither mentions nor implies that the practitioner must give the document to the ‘ultimate user.’” Hunstein would find the provision void for vagueness; Melton and Sears would find the provision not vague, but not applicable to giving a document to a staff member. Bradford v. State, 285 Ga. 1, 673 S.E.2d 201 (February 9, 2009). Conspiracy statute is not unconstitutionally vague for failure to define “overt act.” “An overt act is one commonly understood to be “open,” “manifest,” or “public.” Black's Law Dictionary 1104 (6 th ed., 1990). In addition, OCGA § 16-4-8 further defines the overt act to which it speaks as committed ‘to effect the object of the conspiracy.’ Therefore, in its context, the statute clearly and unambiguously refers to a specific type of open or manifest act made in furtherance of a conspiracy to commit a crime. Given the clarity and specificity of this language, OCGA § 16-4-8 is not unconstitutionally vague, and Bradford was properly placed on notice in this case that her actions were illegal.” Rodriguez v. State, 284 Ga. 803, 671 S.E.2d 497 (January 12, 2009). Georgia Street Gang Terrorism and Prevention Act, OCGA § 16-15-1 et seq., is not unconstitutionally vague. “Vagueness challenges to anti-gang legislation have consistently been unsuccessful where the statute, as properly construed, requires active participation in the gang with knowledge of its criminal behavior, imposes a specific intent requirement, or specifically defines critical terms. [Cits.]” Under the act, “to constitute a ‘criminal street gang,’ a group of three or more persons must ‘engage’ in ‘criminal gang activity’ through its members. An isolated offense by a single member does not fulfill that requirement. We additionally observe that OCGA § 16-15-3(2) does not in any way indicate that this particular requirement is fulfilled merely by ‘evidence of a common name or common identifying signs, symbols, tattoos, graffiti, or attire or other distinguishing characteristics.’” Also, the gang’s “‘criminal gang activity’ or plans for continuation of that activity must be ongoing at the time of the defendant's commission of an enumerated offense.” Accord, In re: K.R.S ., 284 Ga. 853, 672 S.E.2d 622 (January 26, 2009). Jenkins v. State, 284 Ga. 642, 670 S.E.2d 425 (November 17, 2008). Sex offender registration statute, OCGA § 42-1-12, is not unconstitutionally vague. Defendant contends that it is unclear whether persons convicted of attempted rape is required to register. “OCGA § 42-1-12(a)(7) (2005) clearly provided that convictions for rape and crimes “relating to rape” required registration as a sex offender. ‘Even though a statute may be marked by “flexibility and reasonable breadth, rather than meticulous specificity,” if it is nonetheless “clear what the [statute] as a whole prohibits,” the statute is not unconstitutionally vague. [Cit.]’. Id. at 400. See also State v. Old South Amusements, 275 Ga. 274, 276 (564 S.E.2d 710) (2002) (legislature is not required to draft statutes with mathematical precision). Thus, the statute was not unconstitutionally vague.” Santos v. State, 284 Ga. 514, 668 S.E.2d 676 (October 27, 2008). Declares OCGA § 42-1-12, Georgia's sex offender registration law unconstitutionally vague as applied to the homeless. “According to its plain language, OCGA § 42-1- 12 mandates that offenders register a change of residence by providing the sheriff of their county a specific street or route address. The statute, however, contains no objective standard or guidelines that would put homeless sexual offenders without a street or route address on notice of what conduct is required of them, thus leaving them to guess as to how to achieve compliance with the statute's reporting provisions. Statute specifically “defined the term ‘address’ to require offenders to specifically report a ‘street or route address’ and further emphasizing that ‘homeless does not constitute an address.’” “Our decision renders unconstitutional the address registration requirement as applied to homeless sex offenders who, like Santos, possess no street or route address for their residence. It does not exempt such offenders from reporting other information required under the statute and it does not exempt homeless sex offenders who are able to provide a street or route address, such as the address of a shelter at which they are staying.” Carley dissents, would hold that “OCGA § 42-1-12 does not require the sex offender to have an address, although he must report any address which he does possess.” Accord, Volz v. State , 306 Ga.App. 763, 703 S.E.2d 354 (November 10, 2010); Chestnut v. State , 331 Ga.App. 69, 769 S.E.2d 779 (March 11, 2015) (conviction for failure to register under 2009 version of statute reversed; State failed to prove that defendant was staying at a location that had a street or route address). OCGA § 42-1-12 amended in 2010 to allow registrants to report homelessness and sleeping location . In re: D.H., 283 Ga. 556, 663 S.E.2d 139 (June 2, 2008). Statute prohibiting disrupting a public school is not unconstitutionally vague for failing to define “disrupt” and “interfere.” “[T]he phrase ‘disrupt or interfere with the