This case comments upon the recent Ontario Divisional Court decision in Allen v Toronto Star Newspapers Ltd (1997), 36 OR (3d) 201 (Ont Div Ct), focusing upon the issue of ownership of copyright in photogenic works in Canada, and the negative effects that this decision will ahve, if followed in other cases and jurisdictions, upon creators\u27 ability to control their works and to derive full economic benefit therefrom as envisioned under Canada\u27s Copyright Act, RSC 1985 c C-42