Rule 439.2.c

The zone a Game Object is created to can be specified implicitly by the Game Action being performed. Example: “Play a 1 [M] Recruit token” specifies a zone where the token is Created to implicitly, by specifying the token is played and thus created on the chain. Example: “Create a 1 [M] Recruit token” does not specify a zone, so the Recruit token will be created at any location on the board that it can be played to.