I believe in English and Commonwealth systems a chose in action refers to both the right to sue as well as a form of intangible property As far as intangible property is concerned choses in action include things like property in shares bank deposits and book debts As far as the right to sue is concerned the way to enforce property rights against such intangible property IS by suing Hence both definitions are correct and in fact comport to the idea of what a chose in action is Just that the reader writer must take care to note the context in which the phrase is used