If you infringe the copyright on something closed, you do it by spreading that thing when you aren't supposed to. If you infringe the copyright on something open, you do it by refusing to distribute your enhancements to it when you're required to. They're not directly comparable situations.
Freedom goes in two directions. "Freedom to" and "Freedom from". The BSD license is a "Freedom to enhance the code as you wish" license. The GPL licenses are "Freedom from someone enhancing the code without sharing those enhancements". A "freedom to" license is great in the short term; it encourages individual products. A "freedom from" license is great in the long term; it encourages growth of the ecosystem as a whole.
Calling it "theft" is a stretch, just like in other cases of copyright violation. Still, the community is owed a release of the modified code. "Theft" captures the spirit of the situation, even if it's not applicable in the literal sense.
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