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Many recording artists and songwriters never reap the rewards of their work. America's first professional songwriter died in poverty at the age of thirty-seven. At the Congressional level the situation has described recording artists as "one group of creators who get ripped off more than anybody else in any other industry". As we approach 2013, there will be a new line of cases that deal with authors of sound recordings attempting to terminate their copyright assignment to the record companies. While the most efficient and frugal solution would be legislative action, the most probable outcome is expensive, fact-intensive litigation. Congress and the Supreme Court have emphasized the value of predictability in copyright ownership. In this situation, Congress has fallen short of that goal. Sound Recordings do not fit the definition of work made for hire under the 1976 Copyright Act. While analyzing the 2013 terminations, courts should not overlook the congressional intent of creating an inalienable termination right for authors.