Products, equipment, or techniques invented by an employee in the course of his employment. Under the Patents Act 1977 section 39, these belong to the employer if the invention was made in the course of the employee's normal duties and these were likely to lead to an invention or in the course of any duties involving a special obligation to further the employer's business. These provisions cannot be changed in a contract of employment. The employee may, however, be awarded compensation by the Comptroller General of Patents, Designs and Trademarks if the invention is of outstanding benefit to the employer (this virtually never applies). Copyright works also belong to the employer if the employee produces them in the course of his employment (LIFFE Administration and Management v Pinkava  EWCA Civ 217,  ICR 1489).