 But even if Cohen’s account of exploitation avoids commitment to the labor theory of value, it nevertheless remains committed to the Marxian idea that exploitation should be understood as the forced appropriation of surplus value. And there are at least two respects in which this commitment is problematic. First, it is unclear whether exploitation necessarily involves the forced transfer of surplus value. Marx’s account asserts that the laborer is forced to work for capitalists because the only alternative is starvation. But suppose the government provides a safety net sufficient to ensure that workers’ subsistence needs are met. If someone chooses to work in order to earn discretionary income, it still seems possible that they could be exploited by a capitalist who appropriates some of the value of the product the laborer creates (Kymlicka 2002: 179). A laborer can be exploited, we might think, by being paid an unfair wage even if that laborer is not forced to work.