Authorship and ownership in copyright law in Canada is an important and complex topic which lies at the nexus between Canada's Copyright Act, an important body of case law, and a number of compelling policy motives. Analysis of authorship and ownership of copyrightable works in Canada can proceed by examination of the rules determining the initial allocation of copyrights, rules governing subsequent changes in ownership, and finally rules governing complex works such as compilations. Rules determining initial allocation of copyrights Canadian copyright law sets out rules which determine who is to be the first owner of the copyright for a new copyright-able work. The rules cover different groups of people such as the authors of the work, employees who create works in the course of their employment, independent contractors who create works under contracts for services, and academics. It is helpful to think of the rules which set out in initial allocation of copyright as 'default' rules because the whole or a portion of the 'ownership' of the copyright may always be transferred to a different person in a contract of sale. The first owner of the copyright: author Section 13(1) of Canada's Copyright Act states that "[s]ubject to this Act, the author of a work shall be the first owner of the copyright therein." The courts have issued a number of decisions which provide some definition to the concept of who is an author according to Canada's Copyright Act. Two helpful decisions regarding the matter of who is an author are Gould Estate v. Stoddart Publishing Co. Ltd. and Donoghue v. Allied Newspapers Ltd. Gould Estate and Donoghue cases Gould Estate and Donoghue are two cases which help to define what an author is in the terms of the Copyright Act by providing examples of persons who are not authors. It has been stated that "[c]opyright exists in the expression of ideas or information, not in the information of ideas themselves." In Gould Estate, the Canadian pianist Glenn Gould participates in a number of interviews with a freelance writer, John Carroll, who is gathering material for an article about Gould. Without the information from Glenn Gould to John Carroll, there would be no material for the magazine story. Nevertheless, it is Carroll who writes all of the ideas down into a concrete expression. The case makes it clear that the author is not the person who invents the ideas