I would say...it depends on the age and the temperment. As they get older, they get some freedom...but I think ALL puppies need to be confined when you can't watch every move they make. It only takes an instant for an accident that could take your baby forever. Better to be safe than sorry.
If she sees the x-pen or crate as her "safe" place and not an area for being punished, she will enjoy that time much better.
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