As an independent contractor, when a freelancer creates creative expressions such as written or artistic works, they are automatically granted ownership of the copyright for their work. Registration of copyright is not required for ownership of these rights, however litigation against infringement may require registration, as documented in the class action lawsuit, Reed Elsevier, Inc. v. Muchnick, when freelance writers sued publishers for copyright violations, though this case eventually settled for the benefit of freelance writers whether or not they had registered their copyright with the Copyright Office.