In the United States, creator ownership in comics is an arrangement in which the comic book creator retains full ownership of the material, regardless of whether the work is self-published or published by a corporate publisher. In some fields of publishing, such as fiction writing, creator ownership has historically been standard. In other fields—such as comics, recorded music, or motion pictures—creator ownership has traditionally been uncommon, with either work for hire or publisher purchase of the material being standard practice. This article traces the changing standards of the comic book industry. History Early twentieth century In 1906, Richard F. Outcault took his creation Buster Brown from the New York Herald to the New York American. Outcault had not applied for a copyright to Buster Brown, but asserted a "common-law title"—what comics historian Don Markstein asserted is one of the earliest claims to creators' rights. The court decided the Herald owned the Buster Brown name and title and the copyright on the strips it published, but the characters themselves were too intangible to qualify for copyright or trademark. This freed Outcault to continue the strip in the American as long as he did not use the Buster Brown name. 1960s Creator-owned titles began to appear during the late-1960s underground comix movement; these themes were exemplified in the formation of Rip Off Press, the United Cartoon Workers of America (UCWA), and Cartoonists' Co-Op Press. Rip Off Press was founded in 1969 by four men—two of whom were cartoonists Gilbert Shelton and Jack Jackson—as a sort of cartoonists' cooperative, an alternative publishing venue to burgeoning Bay Area publishers like the Print Mint, Apex Novelties, and Company & Sons. 1970s The United Cartoon Workers of America was an informal union organized in 1970 by cartoonists Robert Crumb, Justin Green, Bill Griffith, Nancy Griffith, Art Spiegelman, Spain Rodriguez, Roger Brand, and Michele Brand. Members of the UCWA agreed that all cartoonists would demand the same rate per page of comics, whether they were stars like Crumb or being published for the first time. They also agreed to not work for any publisher who had "cheated" other cartoonists. Dennis Kitchen's Kitchen Sink Press formed the "Local 2 — Milwaukee" branch of the UCWA, and the UCWA brand appeared on a number of comix from that era. Cartoonists' Co-Op Press was a 1973–1974 self-publishing venture by cartoonists Griffith, Spiegelman, Kim Deitch, Jerry Lane, Jay Lynch, Willy Murphy,