Fixation is the process or result of recording a work of authorship in tangible form (Black’s Law Dictionary).  Fixation of a work or object of related rights in material form (including storage in an electronic (computer) memory), must be done in a sufficiently stable form, in a way that on this basis the work or object of related rights may be perceived, reproduced or communicated to the public.  Fixation in material form is not always a necessary pre-requisite of protectability, but the Berne Convention for the Protection of Literary and Artistic Works (1971) allows national copyright laws to make fixation such a condition.  The fixation of traditional cultural expressions in a material form may establish new intellectual property rights in the fixation and these rights may be used indirectly to protect the traditional cultural expressions themselves—such a strategy has been used to protect ancient rock art. It has been argued that the use of the term “expression” could give the impression of a fixation requirement for protection of traditional cultural expressions.