Cramer v. Crestar Financial Corp.
United States Court of Appeals for the Fourth Circuit
67 F.3d 294 (1995)
- Written by Whitney Kamerzel , JD
Facts
From 1985 to 1993, Thomas Cramer (plaintiff) worked for Continental Federal Savings Bank (Continental) as the director of information systems. In 1990 Continental decided to provide point-of-sale (POS) services to customers to help them facilitate purchases using credit cards. Cramer developed the POS software at his home, on his own computers, over several hundred hours, and was responsible for implementing Continental’s POS initiative. A final version of the POS software was created by another Continental employee using Cramer’s initial version. When Continental merged with Crestar Financial Corp. (Crestar) (defendant), Crestar paid Cramer to transfer the POS system to Crestar. However, Crestar did not offer to employ Cramer. Cramer then filed a copyright registration in the POS program and sued Crestar for copyright infringement. The district court granted Crestar’s motion for summary judgment and found that the software was a work made for hire. Cramer appealed.
Rule of Law
Issue
Holding and Reasoning (Per curiam)
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