The termination provisions of Section 203(a) of the Copyright Act are complicated enough when a work in question is finished before the contract in which a grant is made. In those instances, the date of execution of the grant, which is needed to calculate when a termination notice can be sent, is relatively easy to determine. But the analysis of termination timing becomes more complicated when the work is created after the contract is signed. This is not only because the date of creation can be difficult to pinpoint, but also because a recent ruling in the Southern District enhances that date's significance.