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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 is in writing and signed by the owner of the rights conveyed.  17 U.S.C. §§ 201, 204.  Although the employer would not be deemed the “author” under such a transfer, it would gain all of the rights under copyright law.  There is, however, one twist that differentiates an assignment from the ownership resulting from a WMFH: the author (or the author’s heirs) may terminate any assignment at any time during the five-year period beginning at the end of the thirty-fifth year after the t

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