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atlases. 17 U.S.C. § 101.  To be sure, very few of the works for which independent contractors are hired fall into one of these enumerated categories.  Where rights are purportedly transferred using a WMFH Clause, ownership of a work that does not qualify as a WMFH would thus remain with the independent contractor.  In such situations, the second mechanism – assignment – is required to shift ownership to the employer. Assignments Copyright is freely transferable so long as the transfer ...