part thereof", may also lie in compilations. Applying section 13.1 to complex works The layering of copyright raises a number of legal questions. Even if a person owns the copyright in a given compilation by virtue of section 13(1) because that person is the author of the compilation has exercised skill and judgement in the selection or arrangement of the constituent works into a compilation. In order for the owner of the copyright of a compilation not to be infringing the copyright of the constituent works, the statute would have to be interpreted to the effect that the copying the constituent works is not something that "only the owner of the copyright" in the constituent works has a right to do, and that the owner of the compilation also has a right to copy the constituent works. However, this interpretation would also be problematic because it would seem to conflict with another provision in the Copyright Act, namely section 2.1(2). Section 2.1(2) of the Copyright Act Section 2.1(2) provides that "[t]he mere fact that a work is included in a compilation does not increase, decrease or otherwise affect the protection conferred by this Act in respect of the copyright in the work [...]". Professor Ariel Katz has suggested that a more simple and elegant solution to this problem would be to focus on the nature of the permission which gave owners of the copyright in the compilation access to the constituent works in the first place. In other words, a better and more simple answer ought to be found in contract law instead of copyright law. Therefore, it seems that there is room for uncertainty and debate on the topic of ownership in complex works such as compilations. In Robertson v. Thomson Corp., the Supreme Court of Canada issued an opinion in relation to these questions. Robertson v. Thomson Corp. The matter in Robertson was that freelance journalists brought a class action suit against The Globe and Mail newspaper alleging that the newspaper infringed copyright when it uploaded the freelancers' articles onto online databases and CD-ROMs. It went to the Supreme Court of Canada where a trial was held to determine the facts surrounding what if any was the contractual agreement between the newspaper and the freelance journalists in relation to the articles in question. Robertson decided that freelance journalists' copyright can stop the republication of their articles onto databases