Editing Work for hire (section)

==== Analogy to works of the United States government ====

{{Main|Copyright status of works by the federal government of the United States}}

Works created by officers and employees of the [[United States federal government]] as part of their official duties are not subject to copyright protection in the United States. House Report 94-1476, published in connection with the [[Copyright Act of 1976]], explains that "although the wording of the definition of 'work of the United States Government' differs somewhat from that of the definition of 'work made for hire,' the concepts are intended to be construed in the same way."<ref name="HR 94-1476">{{cite wikisource |title=Copyright Law Revision (House Report No. 94-1476) |wslink=Page:H.R. Rep. No. 94-1476 (1976) Page 058.djvu|page=58|publisher=United States House of Representatives}}</ref> Cases regarding the status of works prepared by employees of the U.S. government have been cited in work-for-hire cases: for example, in ''Williams v. Weisser'', a case establishing the [[#Teacher exception|teacher exception]], the court discussed ''Sherrill v. Grieves'', in which a book written by a professor at a U.S. Army officers' school for a course he was teaching was held not to be a "publication of the United States Government" under the Copyright Act of 1909.<ref name="townsend-teacher-exception-2003"/><ref name="holmes-levin-teaching-2000">{{cite journal|url=https://digitalcommons.law.byu.edu/cgi/viewcontent.cgi?article=1110&context=elj|title=Who Owns Course Materials Prepared by a Teacher or Professor? The Application of Copyright Law to Teaching Materials in the Internet Age|last=Holmes|first=Georgia|last2=Levin|first2=Daniel A.|date=2000|volume=2000|issue=1|journal=Brigham Young University Education and Law Journal|pages=165-189|access-date=May 21, 2025}}</ref>