Should menu titles (h1, h2, h3...) be inside or outside the <nav> tag?

According to the HTML5 spec, "nav" is a "section" and a section "is content that defines the scope of headings and footers." The W3C example for the nav section shows h tags in the the nav.

h tags are for the structure of the content of the page. I wouldn't say navigation is part of the content of the page, so it doesn't make sense to me to have h tags in the navigation.