Assignment at Time of Creation

I recall somewhere that there is a holding in which the words "at time of creation" are critical to an automatic copyright assignment between a contractor employee and the employer (not to be confused with a work-for-hire situation in an employer/employee relationship). Can anyone recall the case or comment of the necessity such wording?

Thanks,
Mike Phillips Received on Sat Aug 27 2005 - 00:15:15 GMT