Copyright in works created by employees, in the U.S., Germany and Colombia

Ownership of Copyright in Works Created in Employment Relationships: Comparative Study of the Laws of Colombia, Germany and the United States of America, by Jose Roberto Herrara Diaz, has been published (in English) by Revista la Propiedad Inmaterial. From the abstract:
The ownership of . . . works [created by employees] has been regulated in different ways by the national laws of each country, and the only attempt [at] . . . harmonization has been . . . in the European Community regarding computer programs created in the course of employment. . . . Germany and United States have regulated the subject in their respective national copyright laws. In other countries, such as Colombia, lawmakers have established a legal rule regarding the ownership of moral rights in copyrighted works, but [they have] not define[d] a clear rule on the important issue of the economic rights in such works. This ambiguity has caused legal uncertainty [about] whether these types of rights belong to employees, private contractors, freelancers or employers. . . . [T]his paper [is] a comparative study of the laws of Colombia, Germany and the United States of America.

Hat tip: Media Law Prof Blog