Data leading to the nucleation theory of accommodation of a solute gas by a liquid are reinterpreted in terms of a capillary-wave model, in which the growth of solvent clusters to some critical size is replaced by progressive absorption into a mobile liquid surface, and the cluster-size Variable is replaced by an effective coordination number. The new model accounts for the observed linear relationship between the enthalpy and entropy of activation for accommodation of a wide variety of solutes in water on the basis of the statistical mechanics of the absorption process and provides an estimate of the rate of penetration into the liquid on the basis of the calculated capillary-wave spectrum.