The idea of theft of 'digital goods' is absurd.

Goods are defined as "commodities that are tangible, usually movable, and generally not consumed at the same time as they are produced".

Theft is defined as "the act of stealing; specifically : the felonious taking and removing of personal property with intent to deprive the rightful owner of it"

Access to New York Times articles is not a tangible commodity, and bypassing the paywall in no way deprives the New York Times company of access or of a unit of access to the article.