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Copyrights can be an extremely valuable commodity. Deals exchanging that commodity may be required to be in writing. A copyright holder doesn’t need a written deal to simply grant a non-exclusive license to use a copyrighted work. The exchange is evident, not only by an oral agreement, but through the conduct of the parties, as the copyright holder is not giving up ownership, but merely giving another person permission to use the work. When a copyright holder transfers rights, however, that exchange must be in writing between the parties because the copyright holder is giving up ownership in the copyrights to the acquiring party and thus the Copyright Act requires proof of that exchange.