Friday, March 1, 2013

Silicon Valley's Latest Integrated Circuit: Collaborative Living


The concept of collaborative living, just like the persons sought to live in collaborative living environments, is genius. Why restrict working to a traditional work environment? Why restrict learning to a traditional school or University system? Through collaborative living, people can live, learn and work, all in one place – and that place just so happens to be a veritable think tank.

A pioneer in the concept of collaborative living, is the collaborative living organization Rainbow Mansion. Residents include programmers from Apple and Google, and engineers from NASA. To be accepted into the house, residents must pass an interview process resemblant of the interview process utilized by notoriously tough recruiters such as Facebook and Twitter. The first round screening questionaire, for example, asks questions such as “what are two things you'd like to impact or contribute during your life?” The house hosts talks and presentations by people such as: Roger Penrose (whom you may not have heard of, but who's prestige you'll understand when you hear that he shares an award with Steven Hawking for his contribution to our understanding of the Universe); Lawrence Lessig (professor at Harvard Law School); and Steve Wozniak (who co-founded Apple with Steve Jobs). The house has a laboratory set up in the garage. And several start-ups have been founded there, including a robotics company and a satellite company.

As with Rainbow Mansion, the working concept of any collaborative living environment is that, in order to become a resident, an applicant has to be extraordinary in some way; either a great artist, or musician or programmer or scientist or philosopher. Moreover, it is expected that, once accepted as a resident, that resident must contribute to the household by sharing these talents. The household might throw a hackathon to create an app for purchasing music concert tickets, or embark on a project to convert the old vacuum cleaner into a powerful milkshake maker, and each resident is obliged to participate in this event or project by lending his/her skill set.

A foreseeable issue thus arises. What happens when an event or project results in a copyrightable work or novel invention, worthy of patenting and/or commercialization? A hackathon might result in computer software or programs (such as video games or virtual worlds), which are considered literary and audiovisual works respectively, and are therefore copyrightable works. A project might result in a new machine that is a patentable invention. In such cases, who is entitled to claim ownership of the work or invention?

Under the “work made for hire” doctrine, copyright in a work vests in the person employing the author to produce that work, rather than the author him/herself. Moreover, for inventions not covered by copyright law, courts have found implied-in-fact assignments to exist where employees were hired specifically for the purpose of inventing, or assigned the task of inventing a specific item, process or method. Thus, similar to rights in copyrightable works, under certain circumstances, patent rights may also automatically vest in employers.

Thus, there is precedence for automatic transfer of intellectual property rights from an author or inventor to his/her employer. One might think, how does this apply to collaborative living scenarios, as residents of collaborative living houses are not traditionally employed by the collaborative living organization?

However, already, due to the advent of start-up companies, the traditional concept of employment has been blurred. In the recent case of Just Med v Byce, Byce was treated as an employee for the purposes of the work made for hire doctrine, despite that:
a) he was not paid a salary or benefits;
b) he was not treated as an employee for tax purposes by Just Med;
c) he did not fill out any employment forms; and
d) he was not directly supervised by Just Med.
If the courts are willing to blur the traditional concepts of employment in such a way, to take account of the modern realities of ambiguous work environments, it would seem that it's only a matter of time before a collaborative living organization tests the applicability of the work made for hire and implied-in-fact assignment doctrines to a work authored or item, process or method invented by the residents of a collaborative living home.

As stated previously, it is a condition of entry and stay that a collaborative living resident contribute towards the events and projects run at the collaborative living home. Residents are asked to leave if it is deemed that they are not contributing. So, if contribution towards these events and projects is a condition incumbent to their being a collaborative living resident, then there is grounds for the collaborative living organization to argue that any work or invention produced during their residency arose 'in the course of' their residency, and is thus covered by the work made for hire or implied-in-fact assignment doctrine. If the colloborative living organization succeeds in this argument, ownership in the works or inventions of residents could well vest in the collaborative living organization.

Time will tell how the law plays out. Until then, in the absence of clear laws, collaborative living organizations and residents should take steps to protect their own intellectual property interests.

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