No. Drive-by shootings, in terms of the context in which they're committed and what they're all about, are usually quite directly linked to the primary criminal activities of these organized crime groups: drug trafficking, extortion, protection rackets, a variety of things. The drive-by shootings are part of an effort sometimes to establish turf, which is important to being able to control the drug trafficking in a given area or to deal with rivals in the field, or simply to create an air of intimidation in the community, so that these groups can carry out their criminal activities. So there is usually quite a direct link with the drive-by shooting.
The drive-by shooting doesn't bring the direct financial benefit. But what the courts have said is that the drive-by shooting produces, nonetheless, a material benefit for the organization if it means that the intimidation they create or the direct action taken against a rival gang has fortified their drug trafficking activity or whatever else they're engaged in that does bring them a financial benefit.
The requirement of material benefit, including a financial benefit, has been interpreted as being this indirect fortification of their ability to carry out the crimes that then bring a further benefit.