DDB is a patent cases, and, therefore therefore isn't interpreting the "work for hire" provision of copyright law -- the issue isn't whether an employment contract could transfer exclusive rights to the employer, but whether the employer was entitled to treat the work as a "work for hire" by policy (in copyright, there's a pretty important distinction between a transfer of exclusive rights by contract and a work being a "work for hire" where the original copyright is with the hiring party, this distinction does not exist in patent law); Medsphere wasn't an IP case at all, it was a case about breach of fiduciary duty by a corporate officer; and DSC/Alcatel involves a case where employee conduct at the time evidence that the employee thought that the work was within the scope of an inventions clause (including asking bosses for a waiver of the inventions clause), even though in court assertions were made (but, from what I can find, weakly supported) that would indicate the work was outside the scope. But, also, most of the reporting is around a "duty to disclose inventions" clause, and none indicates anything about work for hire in copyright -- its not at all clear from anything I can find on the case that it addresses scope of employment/work for hire issues, just scope of an enforceable contract clause which may effect a transfer of ownership.
So none of these cases seem to be on point here.
