`For the First Circuit
`
`
`
`
`No. 19-1927
`
`MARKHAM CONCEPTS, INC.; LORRAINE MARKHAM, individually and in
`her capacity as trustee of the Bill and Lorraine Markham
`Exemption Trust and the Lorraine Markham Family Trust; SUSAN
`GARRETSON,
`
`Plaintiffs, Appellants,
`
`v.
`
`HASBRO, INC.; REUBEN KLAMER; DAWN LINKLETTER GRIFFIN; SHARON
`LINKLETTER; MICHAEL LINKLETTER; LAURA LINKLETTER RICH; DENNIS
`LINKLETTER; THOMAS FEIMAN, in his capacity as co-trustee of the
`Irvin S. and Ida Mae Atkins Family Trust; ROBERT MILLER, in his
`capacity as co-trustee of the Irvin S. and Ida Mae Atkins Family
`Trust; MAX CANDIOTTY, in his capacity as co-trustee of the
`Irvin S. and Ida Mae Atkins Family Trust,
`
`Defendants, Appellees,
`
`IDA MAE ATKINS,
`
`Defendant.
`
`
`APPEAL FROM THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF RHODE ISLAND
`
`[Hon. William E. Smith, U.S. District Judge]
`
`
`
`Before
`
`Thompson, Lipez, and Kayatta,
`Circuit Judges.
`
`
`
`
`
`
`
`
`
`Robert M. Pollaro, with whom David Cole, John T. Moehringer,
`and Cadwalader, Wickersham & Taft LLP were on brief, for
`
`
`
`
`
`
`
`appellants.
`
`Joshua C. Krumholz, with whom Courtney L. Batliner, Mark T.
`Goracke, Patricia K. Rocha, Holland & Knight LLP, and Adler Pollock
`& Sheehan P.C. were on brief, for appellee Hasbro, Inc.
`
`Patricia L. Glaser, with whom Erica J. Van Loon, Joshua J.
`Pollack, Thomas P. Burke Jr., Lathrop GPM LLP, and Glaser Weil
`Fink Howard Avchen & Shapiro LLP were on brief, for appellee Reuben
`Klamer.
`
`Christine K. Bush, Ryan M. Gainor, David B. Jinkins, Hinckley,
`Allen, & Snyder LLP, and Thompson Coburn LLP on brief for appellees
`Max Candiotty, Thomas Feiman, Dawn Linkletter Griffin, Laura
`Linkletter Rich, Dennis Linkletter, Michael Linkletter, Sharon
`Linkletter, and Robert Miller.
`
`
`
`
`
`June 14, 2021
`
`
`
`
`
`
`LIPEZ, Circuit Judge. "The Game of Life" is a classic
`
`family board game, introduced in 1960 by the Milton Bradley Company
`
`to great success. This case involves a long-running dispute
`
`between Rueben Klamer, a toy developer who came up with the initial
`
`concept of the game, and Bill Markham, a game designer whom Klamer
`
`approached to design and create the actual game prototype.
`
`Eventually, their dispute (which now involves various assignees,
`
`heirs, and successors-in-interest) reduced to one primary issue:
`
`whether the game qualified as a "work for hire" under the Copyright
`
`Act of 1909. If it did, Markham's successors-in-interest would
`
`not possess the termination rights that would allow them to
`
`reassert control over the copyright in the game. After considering
`
`the evidence produced at a bench trial, the district court
`
`concluded that the game was, indeed, such a work. Plaintiff-
`
`appellants, who all trace their interest in the game to Markham,
`
`challenge that determination. We affirm.
`
`I.
`
`We begin with a summary of the facts, as found by the
`
`district court. In 1959, Bill Markham, an experienced game
`
`designer and the head of a California-based product development
`
`company, was approached by Rueben Klamer, a toy developer with
`
`extensive industry contacts. Klamer had just visited Milton
`
`Bradley's Massachusetts headquarters, where he had been asked to
`
`develop an idea for a product that would commemorate the company's
`
`- 3 -
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`
`
`1960 centennial. While searching for inspiration in the company's
`
`archive, he discovered a copy of the company's first board game:
`
`"The Checkered Game of Life," created by Milton Bradley himself in
`
`1860. The original game was intended to instill its youthful
`
`players with lessons about vice and virtue. Klamer saw potential
`
`in an updated version, modified to reflect contemporary American
`
`society and values. On the trip back to California, Klamer
`
`developed the concept, even scribbling some thoughts on the flight
`
`home. Klamer was more of an ideas person, though, and he needed
`
`help developing the concept and creating a working prototype that
`
`could be pitched to Milton Bradley. Klamer chose Markham's firm
`
`partly because of two talented artists who worked there: Grace
`
`Chambers and Leonard Israel.
`
`Markham and his team started work on the project in the
`
`summer of 1959. To ensure that a product launch coincided with
`
`Milton Bradley's 1960 centennial, they rushed to produce a
`
`prototype in just a few weeks. Markham and Klamer together
`
`contributed key features of the game: play would advance along a
`
`track winding through a three-dimensional game board, with a
`
`spinner determining how far players would move on each turn
`
`(thereby progressing through various "life milestones"). Klamer
`
`visited Markham's firm once or twice per week to offer feedback on
`
`the development of the physical game board and the box cover.
`
`Chambers built most of the prototype board. She constructed
`
`- 4 -
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`
`
`houses, mountains, and the elevated track out of balsa wood,
`
`cardboard, and paper. Israel focused on the art for the
`
`prototype's box cover. He produced various sketches, Markham and
`
`Klamer chose the one they liked best, and Chambers integrated it
`
`into a box cover. As the game took shape, Markham, Klamer,
`
`Chambers, and Israel would all play the prototype together,
`
`suggesting (and vetoing) various rules and refinements. Sue
`
`Markham, Bill's wife and a copywriter by trade, memorialized the
`
`agreed-upon changes in what became the prototype's rulebook.
`
`After approximately six weeks, the prototype was ready.
`
`At a meeting at Chasen's (a famous Hollywood restaurant), Klamer
`
`and Markham pitched it to a group of Milton Bradley executives.
`
`Also present was an associate of Klamer's, Art Linkletter, a well-
`
`known radio and television personality. Klamer and Linkletter
`
`were co-founders of a company called Link Research Corporation,
`
`which developed products and used Linkletter's celebrity to
`
`promote them. Part of the pitch was that Linkletter could help
`
`market the game. The pitch worked. The Milton Bradley executives
`
`liked the game and thought that it had commercial potential.
`
`The parties subsequently entered into two agreements
`
`regarding rights to the game. The first was a license agreement
`
`between Link Research and Milton Bradley. It gave Milton Bradley
`
`the exclusive right to make and sell the game and noted that Link
`
`Research "ha[d] had . . . [the game] designed and constructed."
`
`- 5 -
`
`
`
`The license agreement also gave Milton Bradley the right to use
`
`Linkletter's name and image in promoting the game. In exchange,
`
`Link Research would receive a six percent royalty on sales,
`
`including a $5,000 non-refundable advance. The second was an
`
`assignment agreement between Link Research and Markham. Stating
`
`that Markham had "invented, designed[,] and developed [the] game,"
`
`it assigned "all of [Markham's] right, title[,] and interest in
`
`and to the Game[] to LINK." In exchange, it gave Markham thirty
`
`percent of Link Research's six percent royalty, including a $773.05
`
`non-refundable advance. It also noted that Markham would be paid
`
`$2,423.16 to cover the costs of producing the prototype. In fact,
`
`Klamer had agreed at the beginning of the project to cover
`
`Markham's costs, and Markham had already billed Link Research for
`
`his expenses (including the salaries of Chambers and Israel and
`
`the cost of the materials used to create the prototype). Klamer
`
`ultimately paid Markham's bill from the $5,000 Milton Bradley
`
`advance.
`
`Milton Bradley, meanwhile, began refining the prototype
`
`and made some design changes, often with input from Markham and
`
`Klamer. It ultimately published the game in early 1960. Milton
`
`Bradley applied to register copyrights in the game board and rules
`
`later that year, identifying itself as the author of both.
`
`Separately, Link Research applied for copyright registration of
`
`the game's box, and likewise identified Milton Bradley as the
`
`- 6 -
`
`
`
`author. The game was a hit, and even today remains a money-maker
`
`for Hasbro, which acquired Milton Bradley (and rights to the game)
`
`in the 1980s.
`
`In the decades following publication, however, Markham
`
`and Klamer clashed (in and out of court) over who deserved credit
`
`for creating the game. Generally speaking, Markham felt that he
`
`was not given proper public recognition for his role, and that his
`
`share of the royalties under the assignment agreement was unfairly
`
`low. Markham passed away in 1993.
`
`This litigation is the latest chapter in the dispute
`
`over the origins of the game. Markham's successors-in-interest
`
`sued Klamer, the heirs of Art Linkletter, and Hasbro, seeking
`
`(among other things) a judicial declaration that they possess
`
`"termination rights" under the 1976 Copyright Act. Such rights
`
`give the authors of works the power to terminate the grant of a
`
`copyright after a certain period of time, see 17 U.S.C. §§ 203,
`
`304(c), and 304(d),1 thereby permitting them to extricate
`
`
`1 These various termination provisions apply in different
`circumstances. Here, because the copyright in the game was
`secured, and any relevant grant was executed, before 1978, § 304(c)
`governs. It provides:
`
`In the case of any copyright subsisting in either its
`first or renewal term on January 1, 1978, other than a
`copyright in a work made for hire, the exclusive or
`nonexclusive grant of a transfer or license of the
`renewal copyright or any right under it, executed before
`
`- 7 -
`
`
`
`themselves from "ill-advised" grants made before the "true value"
`
`of their work was apparent. Mills Music, Inc. v. Snyder, 469 U.S.
`
`153, 172-73 (1985). With termination rights, Markham's
`
`successors-in-interest would be able to cancel the original
`
`assignment agreement and presumably negotiate a more lucrative
`
`royalty deal. There is, however, a crucial qualifier. As all
`
`parties agree, termination rights do not extend to "work[s] made
`
`for hire." 17 U.S.C. § 304(c); see also 3 Melville B. Nimmer &
`
`David Nimmer, Nimmer on Copyright § 11.02[A][2] (2020) (noting
`
`that the law "disallow[s] all works for hire from termination").
`
`Accordingly, whether the game qualified as a work for hire became
`
`the focal point of the case.
`
` After a bench trial (which included testimony from
`
`Klamer, Chambers, and Israel), the district court concluded that
`
`the game was a work for hire under the so-called "instance and
`
`expense" test. Specifically, the court found that Klamer "provided
`
`the instance for and b[ore] the expense of the prototype's
`
`invention." As a result, according to the court, Markham's
`
`successors-in-interest lacked termination rights under the 1976
`
`Copyright Act. They now challenge that conclusion on appeal,
`
`
`January 1, 1978, . . . is subject to termination under
`the following conditions: [listing conditions].
`
`17 U.S.C. § 304(c).
`
`- 8 -
`
`
`
`arguing that the district court erred in using the instance and
`
`expense test, and, even under that test, reached the wrong
`
`conclusion. They also challenge the court's failure to strike one
`
`of the defendants' discovery responses.
`
`A. Standard of review
`
`II.
`
`When reviewing a district court's judgment following a
`
`bench trial, we defer to the court's findings of fact (unless
`
`clearly erroneous), but not to its legal conclusions (which we
`
`consider de novo). See Rojas-Buscaglia v. Taburno-Vasarhelyi, 897
`
`F.3d 15, 23 (1st Cir. 2018). A more flexible standard governs so-
`
`called mixed questions of fact and law. See In re IDC Clambakes,
`
`Inc., 727 F.3d 58, 64 (1st Cir. 2013) ("The more fact intensive
`
`the question, the more deferential the level of review (though
`
`never more deferential than the 'clear error' standard); the more
`
`law intensive the question, the less deferential the level of
`
`review.").
`
`B. What work-for-hire test applies?
`
`
`
`
`
`1. Doctrinal background
`
`American copyright law has long recognized that a work
`
`created by an employee belongs to the employer, who is then viewed
`
`as the author and copyright holder. See Bleistein v. Donaldson
`
`Lithographing Co., 188 U.S. 239, 248 (1903). This judge-made
`
`doctrine was "later codified in the Copyright Act of 1909."
`
`- 9 -
`
`
`
`Forward v. Thorogood, 985 F.2d 604, 606 (1st Cir. 1993). However,
`
`the 1909 Act did not provide much detail. It indicated that "[t]he
`
`word 'author' shall include an employer in the case of works made
`
`for hire," 17 U.S.C. § 26 (1976 ed.) (1909 Act), but did not define
`
`"employer" or "works made for hire." As a result, "the task of
`
`shaping these terms fell to the courts." Cmty. for Creative Non-
`
`Violence v. Reid, 490 U.S. 730, 744 (1989).
`
`Initially, courts limited the doctrine to "the
`
`traditional employer-employee relationship," that is, to "a work
`
`created by an employee acting within the scope of employment."
`
`Forward, 985 F.2d at 606. Later, however, courts extended the
`
`doctrine "to include commissioned works created by independent
`
`contractors." Id. In these situations, courts would "treat[] the
`
`contractor as an employee and creat[e] a presumption of copyright
`
`ownership in the commissioning party at whose 'instance and
`
`expense' the work was done." Id.; see also 1 Nimmer on Copyright
`
`§ 5.03[B][1][a][i] (noting that, under the 1909 Act, "the courts
`
`expanded the definition of 'employer' to include a hiring party
`
`who had the right to control or supervise the artist's work"). In
`
`practice, this test often favors the hiring party. See Roger E.
`
`Schechter & John R. Thomas, Principles of Copyright Law § 5.2.1
`
`(1st ed. 2010) (noting that, "[e]ven in situations very far removed
`
`from the typical employer-employee case," the test "was often
`
`satisfied because the hiring party was the one who was the
`
`- 10 -
`
`
`
`'motivating factor' for the project and who had at least a
`
`theoretical 'right to supervise' the work").
`
`In the Copyright Act of 1976, Congress introduced a more
`
`explicit, two-part framework that applied to works created on or
`
`after January 1, 1978 (the effective date of the Act). 17 U.S.C.
`
`§ 101; Forward, 985 F.2d at 605. The 1976 Act defined a "work
`
`made for hire" as either:
`
`(1) a work prepared by an employee within the
`scope of his or her employment; or
`
`(2) a work specially ordered or commissioned
`for use as a contribution to a collective
`work, as a part of a motion picture or other
`audiovisual work, as a translation, as a
`supplementary work, as a compilation, as an
`instructional text, as a test, as answer
`material for a test, or as an atlas, if the
`parties expressly agree in a written
`instrument signed by them that the work shall
`be considered a work made for hire.
`
`17 U.S.C. § 101. By adopting this two-part definition, Congress
`
`seemingly "meant to address the situation of the full-time or
`
`conventional employee in the first provision, and the situation of
`
`the independent contractor in the second." Principles of Copyright
`
`Law § 5.2.2. Significantly, Congress's new approach was friendlier
`
`to commissioned parties than under the 1909 Act, at least in
`
`certain ways. In the absence of an employee-employer relationship,
`
`only specific kinds of works could be treated as works for hire,
`
`and then only if there was a written agreement to do so. See id.
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`- 11 -
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`
`
`The latest relevant development, for our purposes, came
`
`in Community for Creative Non-Violence v. Reid, 490 U.S. 730
`
`(1989). Reid dealt with the proper interpretation of "a work
`
`prepared by an employee within the scope of his or her employment"
`
`-- that is, the first way in which a work can qualify as a work
`
`for hire under the 1976 Act. 490 U.S. at 738 (quoting 17 U.S.C.
`
`§ 101(1)). Noting that the Act did not define "employee," Reid
`
`explained that the term should "be understood in light of the
`
`general common law of agency." Id. at 739-41. In so holding, the
`
`Court rejected an approach to § 101(1), adopted by some circuits,
`
`that had deemed a hired party an "employee" if the hiring party
`
`had "a right to control" or "actual control of" the work. Id. at
`
`742.
`
`
`
`
`
`2. Discussion
`
`Because The Game of Life was created long before the
`
`1976 Act took effect, there is no question that the standard for
`
`a work for hire under the 1909 Act governs. See Forward, 985 F.2d
`
`at 606 n.2 (noting that the 1976 Act "altered the works for hire
`
`doctrine," but only "prospectively"). However, appellants claim
`
`that the instance and expense test -- the prevailing approach under
`
`the 1909 Act for determining whether a commissioned work is a work
`
`for hire -- is no longer applicable, even as to pre-1978 works.
`
`This is so, they argue, because of Reid. Appellants acknowledge
`
`that Reid addressed the 1976 Act, but they maintain that its
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`- 12 -
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`
`
`underlying logic applies equally to the 1909 Act. They argue that
`
`Reid requires courts to read the 1909 Act's reference to
`
`"employer"2 in light of standard agency principles, and thus
`
`forecloses the instance and expense test. In other words,
`
`according to appellants, the work-for-hire doctrine under the 1909
`
`Act is limited to works produced under a traditional employer-
`
`employee relationship defined by principles of agency law, and
`
`does not extend to commissioned works, for which the lower courts
`
`developed the instance and expense test. In that circumstance,
`
`Markham would retain his status as the original author, a status
`
`precluded by the work for hire doctrine, and enjoy the termination
`
`rights that go with that original author status. Appellants thus
`
`urge us (or the district court on remand) to apply the agency law
`
`factors set forth in Reid in order to determine whether Klamer
`
`qualifies as an employer. Upon doing so, they say, it would be
`
`clear that he does not, and the game would therefore not qualify
`
`as a work for hire.
`
`
`2 Reid did not specifically address the meaning of the word
`"employer" because the provision at issue -- the first part of the
`work-for-hire definition in the 1976 Act -- does not use the term.
`See 17 U.S.C. § 101(1) (referring to "a work prepared by an
`employee within the scope of his or her employment"). Nonetheless,
`Reid could fairly be read to mean that the term "employer" also
`should be understood in light of standard agency principles. See
`490 U.S. at 740 (noting that, in the past, "we have concluded that
`Congress intended terms such as 'employee,' 'employer,' and 'scope
`of employment' to be understood in light of agency law").
`
`- 13 -
`
`
`
`Even if we were disposed to appellants' view, however,
`
`it does not account for our own precedent. In Forward, which was
`
`decided four years after Reid, we applied the instance and expense
`
`test to a work governed by the 1909 Act, noting that the test
`
`controlled whether a commissioned work qualified as a work for
`
`hire. See id. at 606. Under our law of the circuit doctrine, we
`
`are bound to apply a prior panel decision that is closely on point.
`
`Tomasella v. Nestlé USA, Inc., 962 F.3d 60, 83 (1st Cir. 2020)
`
`(citing San Juan Cable LLC v. P.R. Tel. Co., 612 F.3d 25, 33 (1st
`
`Cir. 2010)). Facing this obstacle, appellants argue that Forward
`
`is not binding precedent on the validity of the instance and
`
`expense test because the applicability of the test was not
`
`contested there (and, indeed, both the test and Reid were "barely
`
`mentioned" in the opinion). We disagree. As we have often
`
`observed, "'when a statement in a judicial decision is essential
`
`to the result reached in the case, it becomes part of the court's
`
`holding.' The result, along with those portions of the opinion
`
`necessary to the result, are binding." Arcam Pharm. Corp. v.
`
`Faría, 513 F.3d 1, 3 (1st Cir. 2007) (quoting Rossiter v. Potter,
`
`357 F.3d 26, 31 (1st Cir. 2004)).
`
`The facts of Forward plainly demonstrate that the
`
`instance and expense test was essential to the result there. John
`
`Forward was a music aficionado and record collector who became a
`
`fan of a band -- George Thorogood and the Destroyers -- after
`
`- 14 -
`
`
`
`seeing them play at a Boston nightclub in 1975. Forward, 985 F.2d
`
`at 604. Drawing on his industry contacts, Forward arranged and
`
`paid for two recording sessions for the band at Rounder Records,
`
`with the aim of producing a demo tape that would get the attention
`
`of the label. Id. at 604-05. Besides suggesting specific songs
`
`to be recorded, Forward's input was limited to arranging and paying
`
`for the sessions. Id. at 605. Rounder Records liked what it heard
`
`and signed the band to a contract; the band agreed that Forward
`
`could keep the 1976 demo tapes for his own use and enjoyment. Id.
`
`More than a decade later, after the band had achieved wider
`
`success, Forward informed the band that he was planning to sell
`
`the tapes as part of a commercial release. Id. The band objected,
`
`and Forward sought a declaratory judgment that he held copyright
`
`ownership in the tapes. Id. In part, he argued that the tapes
`
`were commissioned works for hire under the 1909 Act because they
`
`were created at his instance and expense -- and, thus, he was the
`
`presumptive copyright owner. Id. at 606.
`
`Applying the instance and expense test, the panel
`
`rejected Forward's argument. Id. The panel found that the
`
`evidence supported the district court's conclusion that "although
`
`Forward booked and paid for the studio time, he neither employed
`
`nor commissioned the band members nor did he compensate or agree
`
`to compensate them." Id. In short, "Forward was a fan and friend
`
`who fostered [the band's] effort [to secure a record contract],
`
`- 15 -
`
`
`
`not the Archbishop of Saltzburg [sic] commissioning works by
`
`Mozart." Id. Put simply, Forward applied the instance and expense
`
`test to reach the outcome it did. Accordingly, the panel
`
`necessarily held that, post-Reid, the instance and expense test
`
`remained applicable to commissioned works under the 1909 Act. That
`
`holding is binding on us here.
`
`Anticipating that we might conclude that Forward is
`
`binding, Markham's successors-in-interest also argue that we are
`
`somehow free to "correct" it because the instance and expense test
`
`is inconsistent with the Court's analysis in Reid. That argument
`
`misses the mark. Although a "controlling intervening event" --
`
`such as "a Supreme Court opinion on the point" -- can allow a panel
`
`to depart from our court's precedent, United States v. Walker-
`
`Couvertier, 860 F.3d 1, 8 (1st Cir. 2017) (quoting United States
`
`v. Chhien, 266 F.3d 1, 11 (1st Cir. 2001)), that is not the
`
`situation here. Reid was decided before Forward, and, indeed, the
`
`Forward panel cited Reid three times. See 985 F.2d at 605, 606,
`
`& 606 n.2. Hence, as a panel, we are not free to abandon Forward.
`
`See United States v. García-Cartagena, 953 F.3d 14, 27-28 (1st
`
`Cir. 2020) (rejecting a party's attempt to cast doubt on an
`
`applicable panel decision based on a case decided before that panel
`
`decision); United States v. Troy, 618 F.3d 27, 36 (1st Cir. 2010)
`
`(noting that Supreme Court cases that precede prior panel decisions
`
`are "impuissant against the law of the circuit rule").
`
`- 16 -
`
`
`
`Moreover, even if we had authority to abrogate a prior
`
`panel opinion on the ground that it misconstrued then-existing
`
`Supreme Court precedent, we would be disinclined to do so in this
`
`case. While appellants' view of Reid has at least one influential
`
`adherent,3 we are skeptical that the Supreme Court, in construing
`
`the 1976 Act, casually and implicitly did away with a well-
`
`established test under a different Act. We also note that the
`
`Second and Ninth Circuits have determined that Reid does not
`
`require abandonment of the 1909 Act's instance and expense test.
`
`See Twentieth Century Fox Film Corp. v. Entm't Distrib., 429 F.3d
`
`869, 878 (9th Cir. 2005), abrogated on other grounds by Rimini
`
`St., Inc. v. Oracle USA, Inc., 139 S. Ct. 873 (2019); Estate of
`
`Burne Hogarth v. Edgar Rice Burroughs, Inc., 342 F.3d 149, 162-63
`
`(2d Cir. 2003).4 And finally, although the Eleventh Circuit noted
`
`that some of Reid's observations were in tension with the instance
`
`
`3 See 1 Nimmer on Copyright § 5.03 [B][2][c] n.157 (arguing
`that the correct view under the 1909 Act is that "A [the hiring
`party] acquire[s] initial copyright in the work, but that this
`occur[s] by implied assignment from B, an independent contractor,
`and not by reason of A's status as 'author' under an employment
`for hire").
`
`4 The Supreme Court has also been presented with, but has
`declined to take up, the question of whether Reid abrogated the
`instance and expense test as to commissioned works. See Pet. for
`Writ of Cert., Dastar Corp. v. Random House, Inc., No. 05-1259,
`2006 WL 849912 at *i (Mar. 28, 2006), cert. denied, 548 U.S. 919
`(June 26, 2006) (presenting the question of "[w]hether under the
`Copyright Act of 1909 a commissioning party is an 'employer'
`entitled to renew the copyright in a work for hire").
`
`- 17 -
`
`
`
`and expense test, see M.G.B. Homes, Inc. v. Ameron Homes, Inc.,
`
`903 F.2d 1486, 1490 (11th Cir. 1990), abrogated in part by Reed
`
`Elsevier, Inc. v. Muchnick, 559 U.S. 154, 160 & n.2 (2010), those
`
`comments were made in a case, like Reid, that was governed by the
`
`1976 Act and thus are dicta. See id. at 1490 n.10.
`
`In sum, we stand by the approach in Forward and reiterate
`
`that the instance and expense test applies to works governed by
`
`the 1909 Act.
`
`C. Application of the instance and expense test
`
`
`Even under the instance and expense test, Markham's
`
`successors-in-interest insist that they prevail. They offer two
`
`arguments, both of which were considered and rejected by the
`
`district court. First, they maintain that the game fails to
`
`satisfy the second prong of the test because it was not made at
`
`Klamer's expense. Second, arguing that the test creates only a
`
`presumption that the work qualifies as a work for hire, they
`
`contend that language in the assignment agreement between Link
`
`Research and Markham is enough to rebut the presumption. We
`
`construe these arguments as raising fact-intensive mixed
`
`questions, which we review with some deference to the district
`
`court. See In re IDC Clambakes, Inc., 727 F.3d at 64.
`
`
`
`
`
`As to the first argument, the evidence amply supports
`
`the district court's finding that the game was created at Klamer's
`
`expense. In general, the expense requirement looks to the parties'
`
`- 18 -
`
`
`
`relative investment of resources in the work and the related
`
`financial risk. See Marvel Characters, Inc. v. Kirby, 726 F.3d
`
`119, 140 (2d Cir. 2013) (noting that the overall purpose of the
`
`expense requirement is to "reward[] with ownership the party that
`
`bears the risk with respect to the work's success"). Here, Klamer
`
`promised at the outset to pay Markham any costs incurred --
`
`regardless of whether Milton Bradley ultimately liked the game and
`
`paid for the rights. Hence, if the dinner at Chasen's had gone
`
`poorly, Klamer still would have been obligated to pay Markham's
`
`costs.5 As a result, Markham's downside was limited.
`
`
`
`
`
`Appellants argue that the game was in fact made at the
`
`expense of Milton Bradley, not Klamer, with the result that Klamer
`
`cannot satisfy the instance and expense test. They seize on the
`
`district court's passing remark that "[a]n argument could have
`
`been made (but was not)" that the game was made at the expense of
`
`Milton Bradley, as "it was Milton Bradley that, once it accepted
`
`the Game, paid Klamer $5,000 and bore the risk of its failure to
`
`sell to the public." Markham Concepts, Inc. v. Hasbro, Inc., 355
`
`F. Supp. 3d 119, 129 n.5 (D.R.I. 2019). But the district court's
`
`
`5 Appellants claim that Klamer's "alleged" oral promise to
`reimburse Markham was "unenforceable," and thus "if the deal to
`sell the Game had fallen apart, Klamer could have walked away with
`no legal obligation to actually reimburse [Bill] Markham." But
`they provide no factual basis for the assertion that the alleged
`promise was never made and no legal support for the notion that
`such an oral promise is unenforceable.
`
`- 19 -
`
`
`
`remark focuses on a later stage in the chronology, after the
`
`creation of the work. No doubt, after Milton Bradley paid for the
`
`rights to the game, it ran the risk of not recouping its
`
`investment. But at the more relevant time period -- when the
`
`prototype was being developed -- it was Klamer who bore the primary
`
`risk, as he was on the hook for the costs if Milton Bradley passed
`
`on the game.
`
`As for Markham himself, it is true that he was paid in
`
`the form of a royalty, rather than a sum certain, which "generally
`
`weighs against finding a 'work for hire' relationship." Urbont v.
`
`Sony Music Entm't, 831 F.3d 80, 90 (2d Cir. 2016). However, the
`
`form of payment is "not conclusive," Warren v. Fox Family
`
`Worldwide, Inc., 328 F.3d 1136, 1142 (9th Cir. 2003), and
`
`distinguishing between a royalty and fixed sum payment can be "a
`
`rather inexact method" of determining which party bears the main
`
`financial risk. Marvel Characters, 726 F.3d at 140. In this case,
`
`we think it significant that Markham's initial royalty payment
`
`($773.05) was a non-refundable advance, meaning that he could keep
`
`the money even if the game did not sell a single copy. In that
`
`respect, the arrangement resembled payment of a sum certain plus
`
`a running royalty, rather than a pure royalty deal. See Warren,
`
`328 F.3d at 1142-43 (finding a work-for-hire relationship when the
`
`hired party was paid a fixed sum and a royalty); cf. Picture Music,
`
`Inc. v. Bourne, Inc., 314 F. Supp. 640, 651 (S.D.N.Y. 1970), aff'd,
`
`- 20 -
`
`
`
`457 F.2d 1213 (2d Cir. 1972) ("[T]he fact that the author was
`
`obliged to repay advances on royalties which were never accrued is
`
`an indicant that the relationship was not an employment for
`
`hire[.]" (emphasis added)). Overall, we find no error, clear or
`
`otherwise, in the district court's determination that the game was
`
`made at Klamer's expense.6
`
`The second argument -- that the assignment agreement
`
`rebuts the presumption created by the instance and expense
`
`test -- presents a closer question. Some cases suggest that a
`
`contemporaneous agreement can clarify that a work, even if made at
`
`the instance and expense of another, is not a work for hire (and
`
`therefore that the hired party remains the "author," entitled to
`
`termination rights). Assuming that a contemporaneous agreement
`
`
`6 Appellants argue that the district court's factfinding was
`flawed because the court credited Israel's and Chambers' testimony
`at trial (which emphasized their and Sue Markham's contributions
`to the game) over contemporaneous written evidence and prior
`statements (which reflected a larger role for Bill Markham). But
`even if the court erred by giving greater weight to the trial
`testimony
`--
`and
`thus
`understating
`Bill
`Markham's
`contributions -- that mistake would be immaterial to the instance
`and expense inquiry as to Klamer. As described above, that
`doctrine does not consider whose hands-on efforts produced the
`work -- it focuses on who paid for and directed the work.
`Regardless, we are unpersuaded that there was error. Appellants
`were free to impeach the testimony they criticize. Thereafter, it
`was the district court's job to sort through the evidence and
`decide what and who was credible. See, e.g., Carr v. PMS Fishing
`Corp., 191 F.3d 1, 7 (1st Cir. 1999) ("[I]n a bench trial,
`credibility calls are for the trier.").
`
`- 21 -
`
`
`
`could indeed alter the game's work-for-hire status,7 the
`
`independent contractor bears the burden of showing that such a
`
`contrary agreement was made, see Playboy Enters., Inc. v. Dumas,
`
`53 F.3d 549, 554–55 (2d Cir. 1995), and courts generally demand
`
`clear and specific evidence of such an agreement, see Lin-Brook
`
`Builders Hardware v. Gertler, 352 F.2d 298, 300 (9th Cir. 1965)
`
`(requiring "an express contractual reservation of the copyright in
`
`the artist" to rebut the presumption); see also 1 Nimmer on
`
`Copyright § 5.03[B][2][c] (requiring "persuasive evidence" of a
`
`contrary agreement).
`
`Markham's successors-in-interest point to two parts of
`
`the assignment agreement which, they say, overcome the
`
`
`7 We merely assume this point because the cases explaining
`how an agreement affects the work-for-hire designation are
`inconsistent, and this case does not require us to make a choice.
`Some cases do suggest that an agreement can rebut the presumption