In what circumstances have courts overturned convictions of grand theft by possession of access card numbers?

In People v. Shabtay (2006) 138 Cal.App.4th 1184, 42 Cal.Rptr.3d 227, a case originally relied upon by defendant, the defendant was convicted of two counts of grand theft by possession of access card numbers of 11 victims. The Shabtay court held that the plain language of section 484e, subdivision (b)defining an offense of grand theft where a person within any consecutive 12month period, acquires access cards issued in the names of four or more persons which he or she has reason to know were taken or retained with intent to defraudprecluded multiple convictions where the prosecution alleged the defendant acquired all the access cards within a consecutive 12month period. (Id. at pp. 1189, 1191, 42 Cal.Rptr.3d 227.) The Shabtay court reversed the conviction on one of the two counts. (Id. at p. 1192, 42 Cal.Rptr.3d 227.)