In New York Times Co. v. Tasini, involving the electronic database reproduction of previously published newspaper articles, the Supreme Court held that:
a. electronic reproduction is not subject to the Copyright Act
b. the publisher newspaper had the reproduction rights since they were \"works for hire\"
c. the publisher newspaper had the reproduction rights under the Copyright Term Extension Act of 1998
d. none of the other choices
e. the publisher newspaper had the reproduction rights as derivative works