Singh v. Ashcroft, 386 F.3d 1228 (9th Cir. Oct. 21, 2004) (Oregon Revised Statute 166.065(1)(a)(A), punishing intentionally harassing or annoying another person by subjecting that person to offensive physical contact is not a crime of violence, and therefore not a crime of domestic violence for immigration purposes, since the force required to commit the offense, including spitting, is not necessarily "violent" force).