What standard do juries apply to determine whether property is a 'thing of value of the United States' once distributed to a private, non-government, third party?

18 U.S.C. § 641 criminalizes theft of a “thing of value of the United States.” The Federal Circuits apply different and inconsistent tests to determine whether property is a “thing of value of the United States” once distributed to a private, non -governme nt, third party. As such, Mr. Zhao presents the following: What standard do juries apply to determine whether property is a “thing of value of the United States” once distributed to a private, non -government, third party?