California, United States of America
The following excerpt is from People v. Gulizia, E064775 (Cal. App. 2016):
be committed by false pretenses or by embezzlement, as well as by a taking. (See People v. Vidana (2016) 1 Cal.5th 632, 639; People v. Williams, supra, 57 Cal.4th at p. 787.) Moreover, "commercial establishment" encompasses more than the ordinary retail store that one would picture as the scene of a shoplifting. (See In re J.L. (2015) 242 Cal.App.4th 1108, 1114.) Contrariwise, we see no indication in the language of the statute that it was intended to exclude acts simply because they may look more like identity theft than everyday shoplifting.
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