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How is the ownership of a work made for hire determined?

When an employee creates a copyrighted work, there are two methods to decide who should own the copyright. In common law countries like the U.K. and the U.S., where copyright is viewed more as a property right, a company that invests in and creates a work may be considered the original copyright owner or even the author. If no agreement states otherwise, a work made for hire's copyright typically belongs to the company. In civil law countries such as France and Germany, a work is considered an extension of the author's personality and spirit, meaning only natural persons can be authors. Consequently, the copyright belongs to the author of a work for hire, while the Company may obtain or be assigned the copyright through contractual terms or by operation of law.

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