Web Site Framing: Copyright Infringement through the Creation of an Unauthorized Derivative Work

This article argues that the framing of others' sites on the World Wide Web-the trapping of another's Web site within one's own site, sometimes known as "in-line" linking-creates a derivative work and is, thus, copyright infringement, when the derivative work was created without permission of the copyright holder. Such linking alters the framed Web site, modifies it, re-packages it in a way its author did not intend and transforms it, misrepresenting the author's work in the process, either by attributing the work to someone else or attributing a creation to the author that the author did not produce.