A work is considered a joint work if it is a "work prepared by two or more authors with the intention that their contributions be merged into an inseparable or interdependent parts of a unitary whole." Thus, to be considered a joint work, each author must contribute original expression and the authors must have intended that the work be considered a joint work. For example, in "Gordon v. Lee", an architect and the president of a construction venture were not considered joint authors both because the president, who had no background in architecture, contributed no original expression and because there was no intent on the part of the architect to make the president a joint author. On the other hand, two architects in the same design firm who worked together to produce the designs were considered by the court to be joint authors both because "[n]either person was exclusively responsible for any of the designs, and the details were used from one design to another" and because the architects stated that the design was a "collaborative effort". Although copyright ownership generally vests in an architect who designs a work, the Copyright Act specifies an exception called the "work-made-for-hire" doctrine. Under this doctrine, an employee who prepares a design within the scope of his or her employment will not be the author of the work. Rather, the employer is considered the author and copyright owner of the design. Despite this exception, an architect's work is rarely considered a work-made-for-hire because to be considered an "employee", several factors are considered, the most important being whether the person received employee benefits and was treated under tax law as an employee. Architects rarely receive such benefits from the person who hired them and therefore generally own the copyright in the works themselves. However the architect's employee, even if they alone executed the work, typically do not own the copyright. For example, in "Bonner v. Dawson", an architect's work was not considered a work-made-for-hire, although hired by the client, because he was "clearly in the capacity of an independent contractor rather than an employee". Under (a), a "transfer of copyright ownership" can occur if it is "in writing and signed by the owner of the rights conveyed or such owner's duly authorized agent". Thus, ownership in an architectural work can be transferred by contract. For instance, in "Dellacasa v. John Moriarty & Associates", a subcontractor's shop drawings were held to have been transferred to the general contractor where the contract stated that the general contractor would "retain all common law, statutory, and other reserved rights, in addition to the copyright (including, without limitation, the right to create derivative works therefrom)."