In People v. Spatarella, 34 NY2d 157, 162, 313 NE2d 38, 356 NYS2d 566 (1974), the defendant was convicted, among other things, of the crimes of grand larceny in the first degree by extortion (then Penal Law 155.40) and petit larceny (Penal Law 155.25). Specifically, he was convicted of using threats of physical injury to coerce the victim Ugenti to relinquish a contract to pick up refuse at a particular restaurant. On appeal, the defendant argued that a customer or service contract is not a thing or property capable of being delivered and that "property," for purposes of the statutes in question, refers only to tangible items such as money or objects of value (Spatarella, 34 NY2d at 161). The Court of Appeals disagreed. Describing the defendant's arguments as "overly literal," the Court held that "business is property, as much so as the articles themselves which are included in its transactions" (id. at 161-162).