While the entire Copyright Clause has been the subject of extensive academic and judicial dissection, two phrases in particular are relevant to this discussion. "Author" means not only the narrow definition of a writer, "but rather [has] reach necessary to reflect the broad scope of constitutional principles." "[T]he term, in its constitutional sense, has been construed to mean an 'originator," 'he to whom anything owes its origin."' Thus, under this broad construction, an "Author" means anybody who creates an original work; that is, produces something "of one's own independent efforts".
Okamoto, Scott T.
"Musical Sound Recordings as Works Made for Hire: Money for Nothing and Tracks for Free,"
University of San Francisco Law Review: Vol. 37
, Article 8.
Available at: http://repository.usfca.edu/usflawreview/vol37/iss3/8