"[w]here, under any partial assignment of copyright, the assignee becomes entitled to any right comprised in copyright, the assignee [...] shall be treated for the purposes of this act as the owner of the copyright [...]" Generally, assignments are distinct from exclusive licenses because exclusive licenses are revocable by the owner of the copyright and because exclusive licensees cannot transfer their rights without authorization from the owner. Euro-Excellence v. Kraft One complicated legal matter is the relationship between exclusive licenses and assignments. In Euro-Excellence Inc. v. Kraft Canada Inc., the Supreme Court of Canada considered the question of whether the breach of an exclusive license by a copyright owner would be copyright infringement or merely breach of contract. The deeper question here is whether assignments are really different from exclusive licenses in law, or whether they are two names for the same thing. Dissenting position in Euro-Excellence While maintaining that there was some distinction between assignments and exclusive licenses, the dissent would have held that exclusive licensees had the right under the Copyright Act to sue the original owner of the copyright for copyright infringement. The dissent based this position on section 2.7 of the copyright act, which states that an "exclusive license is an authorization to do any act that is subject to copyright to the exclusion of all others including the copyright owner." According to the dissent, it would rob section s.2.7 of effect and meaning if an exclusive licensee were to be held to have no right of action as against the copyright owner, because in that case the exclusive licensee would have no way to give effect to his right to exclude all others including the copyright owner. The decision in Euro-Excellence maintains the distinction between assignments and exclusive licenses. Ownership in complex works such as compilations There are a number of provisions in the Copyright Act which relate to collaborative works and compilations. For example, both the terms "collective work" and "compilation" are listed among the defined terms in section 2. It is specified that the term compilation may mean "a work resulting from the selection or arrangement of literary, dramatic, musical or artistic works or of parts thereof [...]" Given that a compilation is defined as a work, it is clear that copyright as defined in section 3(1) of the act, namely "the sole right to produce or reproduce the work or any substantial