For more information on the registration of transfers and other copyright-related documents, please see Copyright Office Circular 12: Registration of Transfers and Other Documents. A non-exclusive agreement to license a non-exclusive agreement does not need to be in writing to be valid. The fact that non-exclusive licenses do not need to be written and can be implied on the basis of your behavior is why they are referred to as implied licenses. The user of the copyrighted material obtains certain rights in its use, but these rights extend only to the extent that the copyright owner would have agreed to have them used if the contract had been negotiated. In 2017, the 9th Court of the Appeals Circuit was created in Johnson v. Storix confirmed a copyright transfer that was not used for the written assignment.  In this case, author Anthony Johnson sold software as an individual entrepreneur and founded his company in 2003 as Storix, Inc. The court upheld a jury decision that Johnson transferred the copyright to the company when it was founded, based on an annual report he wrote and signed, in which he stated that he had transferred “all the assets” of his individual company. The jury rejected Johnson`s claim that he only wanted to transfer the license to sell the software and also decided that Johnson became a rental factory when the company was founded, which also caused all rights to his derivative works to be lost.