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the Company $7,800 allow the jury to infer the value of the labor and materials that Stratacos had provided. The evidence did not establish that what the new contractor did under its contract was limited to completing the promised services that Stratacos had left undone under his contract.” Green v. State, 301 Ga.App. 866, 689 S.E.2d 132 (January 6, 2010). Evidence supported defendant’s conviction for theft by deception. “[T]here was evidence that Green told [victim] Gillis that her husband had clear title to the trailer and had owned it for two years, when she knew that, in truth, her husband had taken the trailer from Moore's unattended house within the month preceding, and then accepted $500 as partial payment for the trailer from Gillis. The evidence authorized the jury to find beyond a reasonable doubt that Green obtained $500 from Gillis by deceptive means. Drake v. State, 274 Ga.App. 882, 883(1), 619 S.E.2d 380 (2005) (evidence authorized conviction for theft by deception where the defendant represented himself as the legal owner of stolen tools and sold them to a pawn shop); Watson v. State, 252 Ga.App. 244, 247(3), 555 S.E.2d 896 (2001) (evidence authorized conviction for theft by deception where the defendant stole a boat trailer and then sold it to the victim).” Campbell v. State, 286 Ga.App. 72, 648 S.E.2d 684 (June 22, 2007). Conviction for theft by conversion reversed; evidence was insufficient to establish contract for brokerage services as alleged in the indictment. Evidence showed that victim gave defendant money for a credit check and first month’s rent on a house; defendant represented that she was a realtor acting on behalf of the owner. The next day, the victim discovered that the house was being foreclosed. “The state in this case elected to base its accusation on a promise of brokerage services, rather than on one of the other forms of deception set out in OCGA § 16-8-3(b). Thus, the state was required at trial to show a definite contract between [victim] Price and Campbell for brokerage services.” While the alleged broker’s services were sufficiently established, “[t]here is no evidence in the record, … concerning whether Price agreed to provide the agent any consideration for these services or what that consideration was to be. A contract requires consideration between the parties, [cit.] and a promise without consideration is unenforceable. [Cit.] Price testified that the $975 she gave the agent was a deposit on the first month’s rent on the house. There is nothing in the record to show that any portion of the first month’s rent was to go to the agent as consideration for her services . [fn.] … The state argues on appeal that it is ‘common practice and common knowledge’ that a buyer’s agent normally receives consideration from the seller through a commission, but at trial the state offered no evidence as to this practice either generally or in this particular transaction. Moreover, in White & Associates v. Decker & Hallman, P.C., 203 Ga.App. 14, 15(1) (416 S.E.2d 352) (1992), we declined to infer terms of a brokerage contract from industry standards, instead stating that ‘not only did [defendant] fail to adduce evidence regarding the existence and scope of the custom and usage of realty standards, it is well established that where there is no contract, proof of usage will not make one.’ Id. at 15 (citations and punctuation omitted). Without consideration for brokerage services there can be no brokerage contract, and without a definite brokerage contract there can be no theft by deception based upon a promise of brokerage services. We thus find the evidence insufficient to support Campbell’s conviction for theft by deception.” Jones v. State, 285 Ga.App. 822, 648 S.E.2d 133 (June 14, 2007). Evidence was sufficient to support defendant’s conviction as a party to theft of services. Defendant obtained cell phone from store employee by paying him on the side. “The evidence permitted the jury to infer: (1) Jones knew that, were he truthful in providing required information to Young’s employer, he could not open an account without paying a significant deposit; (2) Jones knew that in providing him a phone, it was necessary for Young to provide his employer with false information, either explicitly or implicitly; (3) by paying $50 to Young, Jones encouraged, hired, or procured him to engage in this deception; and (4) Jones did not intend to pay for the communications services he would be receiving. This evidence was sufficient to convict Jones as a party to the crime of theft by deception.” Scott v. State, 277 Ga.App. 876, 627 S.E.2d 904 (March 3, 2006). “Even though [victim] was able to stop the crime prior to the actual funding of the check and never lost the amount of the check, the charge of theft by deception is still valid. It is not necessary for the state to prove any pecuniary loss on the part of ... the victim of the theft by deception.... The crime of theft by deception was complete when Scott received the check and tendered it to the dealer. A rational jury was authorized to find Scott guilty beyond a reasonable doubt of theft by deception because Scott deceived [victim] and subsequently obtained a draft check from the company for $18,710.90. [Cits.]” Marks v. State, 280 Ga. 70, 623 S.E.2d 504 (December 1, 2005). Evidence was sufficient to convict defendant of theft by deception of defendant’s motor vehicle even though “title was never signed over to a transferee and because the vehicle ultimately was returned to Mr. Stewart. The evidence established that Marks caused Mr. Stewart to sign the title, and that Marks took possession and control of the vehicle in exchange for ‘legal work,’” where defendant falsely posed as an