Ilchuk v. Attorney Genera, ___ F.3d ___, 2006 WL 90124 (3d Cir. Jan. 17, 2006) (Pennsylvania conviction of convicted of theft of services, in violation of 18 Penn. Consol. Stats. Ann. 3926(b) ["guilty of theft if, having control over the disposition of services of others to which he is not entitled, he knowingly diverts such services to his own benefit or to the benefit of another not entitled thereto."], with a six- to 23-month sentence to home arrest, constituted theft offense aggravated felony under INA 101(a)(43)(G), 8 U.S.C. 1101(a)(43)(G), for immigration purposes because the offense requires the taking or exercise of control over something of value knowing that its owner has not consented).