ISSUE:
Whether under common-law agency principles, does one who creates an artwork at the directive of another retain copyright upon it unless that other had employed the artist?
RULE:
Doctrine of Works Made for Hire: According to this doctrine, for works made for hire, the author is not the person who has created the work. Instead, the person who hired the individual is the author and the owner of the copyright of the work itself.
Under common-law agency principles, one who creates an artwork at the directive of another retains copyright upon it unless that other had employed the artist.