In Kotis v. Nowlin Jewelry, Inc., 844 S.W.2d 920, 923 (Tex. App.--Houston 14th Dist. 1992, no writ), Sitton purchased a watch from Nowlin Jewelry with a forged check and then sold the watch to Kotis, who asserted that he was a good-faith purchaser. Kotis, 844 S.W.2d at 921-22. In determining whether Sitton had voidable title, and the ability to transfer good title to Kotis, the Fourteenth Court of Appeals distinguished between a thief, who wrongfully takes goods against the will of the owner and has void title, and a swindler, who fraudulently induces the owner to deliver goods voluntarily and has voidable title. See id. at 922-23. Because Sitton did not obtain the watch against Nowlin Jewelry's will, but instead used a forged check to fraudulently induce Nowlin Jewelry into delivering the watch, Sitton received voidable title and could pass good title to Kotis, if Kotis qualified as a good-faith purchaser. Id. The Fourteenth Court noted, however, that section 2.403(a)(4) only applies to "cases involving acts fraudulent to the seller such as where the seller delivers the goods in return for a forged check." Id. at 923.