In the United States a "work for hire" (published after 1978) receives copyright protection until 120 years after creation or 95 years after publication, whichever comes first. This differs from the standard U.S. copyright term, life of the author plus 70 years, because the "author" of a work for hire is often not an actual person, in which case the standard term would be unlimited, which is unconstitutional.[9] Works published prior to 1978 have no differentiation in copyright term between works made for hire and works with recognized individual creators.