Not necessarily. While theft will always be conversion in the civil lawsuit world, not all types of conversion must necessarily be theft. Other types of conduct that can be included in this claim include but are not limited to: destroying the plaintiff's property; refusing to record the proper ownership after a sale (e.g., of a car); altering property in such a way that it cannot be properly used or used at all; or failure to deliver funds or property a person has the duty to deliver. Conversion has more to do with actual interference with the plaintiff's ownership and possession rights rather than just theft.