[17] In this case, author Anthony Johnson sold software as an individual entrepreneur and founded his company in 2003 as Storix, Inc. The court upheld a jury decision that Johnson transferred the copyright to the company when it was founded, based on an annual report he wrote and signed, in which he stated that he had transferred «all the assets» of his individual company. The jury rejected Johnson`s claim that he only wanted to transfer the license to sell the software and also decided that Johnson had become a rental factory when the company was founded, which also deprived all rights of his derivative works. This is the first case where a document, not even a contract or agreement that contains no reference to copyright, has been considered a copyright transfer «note or memorandum» and the first time that a single owner of a business has been designated as a rental work for copyright purposes. [dubious — discuss] This is a lesson that a «writing» required by copyright law does not necessarily have to be «clear», but may contain ambiguous language that can be interpreted by the alleged handling of the transaction by third parties. Therefore, critics[28] argue that copyright in scientific research is largely ineffective in its proposed use, but that it has often been wrongly acquired and is practically contrary to its fundamental purpose of contributing to the protection of authors and the pursuit of scientific research. Plan S requires authors and their respective institutes to retain copyright in articles without transferring them to publishers; something that is also supported by OA2020. [Note 4] Researchers could not find evidence that the transfer of copyright is necessary for publication or, in all cases where a publishing house has exercised copyright in the best interests of authors.. .

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