According to the "work made for hire doctrine" of the Copyright Act, the creators of artistic and literary works are not legally granted ownership of works created in the course of employment; ownership rests with the employer. However, through "de facto" custom and court dicta, academics may enjoy a "teacher exception" that grants them copyright ownership of publications and course materials. Though there are several benefits behind this practice, the question of intellectual property ownership has blurred as institutions are investing in distance education and commissioning faculty members to create online courses.