ork for hire? Relevant facts. Under the 1976 Copyright Act, the copyright completed by an employee for an employer belongs to the employer and one completed by an independent contractor belongs to the independent contractor-author, unless the work is specially ordered or commissioned and there is a written agreement between the parties which specifies that the work is to created as "a work made for hire." 17 U.S.C. sec. 201. By the time Parker created the research report on Paine, he was no longer an employee of the governor, but rather was in business for himself as an opposition research political consultant, a new breed of political consultant which began to emerge in the late 80s and early 90s. Shalit said that in 1994 "opposition research is now the fastest growing discipline among campaign professionals," their numbers having tripled since 1990. (Ruth Shalit, "The Oppo Boom," New Republic, 16 (3 January 1994)).
The Supreme Court made it clear in the case
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