Some observers have criticized the substitution of the phrase "pursuit of Happiness" for "property," claiming that Jefferson sacrificed precision and candor in favor of a more rhetorically appealing phrase. As should be clear from our discussion of property in Section 4 (p. 4.5:13), property as defined in a free market consists of precisely those values that an individual must own in order to enjoy full freedom of action, i. e, to pursue happiness. Jefferson's phrase therefore not only upholds the right to property, but provides it with its proper ethical justification—an approach entirely appropriate to a manifesto such as the Declaration of Independence.