United States v. Grajeda, 581 F.3d 1186, 1191 n.4 (9th Cir. Sept. 21, 2009) (decisions interpreting the "crime of violence" definition contained in the "elements" prong of U.S.S.G. 2L1.2(b)(1)(A)(ii), are fully applicable to immigration cases turning on the practically identical "crime of violence" definition contained in 18 U.S.C. 16(a), which is used to define "crime of violence" aggravated felonies under INA 101(a)(43)(F), 8 U.S.C. 1101(a)(43)(F): "Like the element prong in 2L1.2, the crime of violence definition in 16(a) includes any "offense that has as an element the use, attempted use, or threatened use of physical force." 18 U.S.C. 16(a); U.S.S.G. 2L1.2, cmt. n. 1(b)(iii) (same). The sole difference is that the 16(a) definition is inclusive of force "against the person or property of another," whereas the Guidelines definition covers only force "against the person of another." Id. (emphasis added). Section 16(b) offers an additional definition, based on the "risk that physical force ... may be used" that is not included in the 2L1.2 definition. 18 U.S.C. 16(b) (defining as a crime of violence "any other offense that is a felony and that, by its nature, involves a substantial risk that physical force against the person or property of another may be used in the course of committing the offense").") (emphasis in original); see United States v. Narvaez-Gomez, 489 F.3d 970, 976 (9th Cir. 2007).