I am fine with this phrasing. Nevertheless, Bjarne's scenario dealing with gravitational time dilation is outside the domain of applicability of Newtonian gravity.
I disagree here. While the gravitational force between a massive object and a massless object is 0 according to Newton's laws it doesn't take force to accelerate a massless object. So the acceleration of massless objects in Newtonian gravity is still given by a=GM/rē.