 A different strategy for justifying intellectual property rights begins with the claim that individuals are entitled to control the fruits of their labor (Locke 1690; Hettinger 1989; Becker 1993; Gordon 1993; Moore 1998b; Hughes 1988; Palmer 2005; Himma 2005a, 2006, 2008, 2013; Merges 2011). In general, the intuition is that the person who clears unowned land, cultivates crops, builds a house, or creates a new invention obtains property rights by engaging in these activities. Laboring, producing, thinking, and persevering are voluntary, and individuals who engage in these activities are entitled to what they produce. Subject to certain restrictions, rights are generated when individuals mix their labor with an unowned object. Restrictions or limits on acquisition include a labor requirement, a non-waste requirement, and the “enough and as good” proviso (Locke 1690). Labor, for Locke, is best understood as metaphor for productive activities needed to sustain and promote human flourishing (Mossoff 2012). The non-waste requirement invalidates a property claim if the appropriator takes more than she can consume or use without spoilage. Unlike the labor metaphor, spoilage for Locke means rotting or the destruction of an existing good useful for sustaining human life. Finally, the “enough and as good” proviso is best illustrated by an example Locke gives. When someone takes a drink of water from a river it is as if he takes nothing at all. His fellows are, all things considered, unaffected by this acquisition.