the business of whoever is paying her." Journalists' exception The exception for journalists is provided within the text of s.13(3) itself. The provision states that in the absence of any agreement to the contrary, journalists would retain a "right to restrain the publication of the work, otherwise than as part of a newspaper, magazine, or similar periodical." In other words, publishers of newspapers have first ownership of copyright over the newspaper as a whole compilation and over the individual articles within it, but the authors of newspaper articles must give permission before a person can republish the article in another format. Academic exception The exception of academics from section 13(3) which makes the academic and not the academic's employer the owner of first copyright in an academic's work and teaching materials is not specifically provided for in statute. Dolmage v. Erskine provides a succinct account of its source: "Academic exception is an implied 'agreement to the contrary' within the meaning of s. 13(3) of the Act." This agreement to the contrary of the terms of section 13(3) need not be written by the academic and the employer into the contract of employment at the time of contract formation, but instead is implied after the fact by the court based on the notion that such is the overwhelming practise in academic institutions and that the parties probably contemplated such a term at contract formation. While this appears to be the custom at the college/university level, whether it applies to high school or other education settings is unsettled in Canadian law. Collective bargaining now tends to resolve this issue. Joint Authorship Vaver states that joint authors will be the first co-owners of a copyright. Presumably, this rule flows from section 13(1) of the Copyright Act. Section 2 of the Copyright Act provides a definition of a work of joint authorship as work in which "the contribution of one author is not distinct from the contribution of the other author [...]" This definition distinguishes works of joint authorship from collective works such as compilations, where it may be evident that the original contribution of the author of one of the constituent works would be distinct from the original contribution of the compiler who arranged and selected the constituent works into a compilation. However, if all of the authors participated in an indistinguishable manner in creating the constituent works and in selecting and arranging