>you can't copyright names, titles, or short phrases //
That's not quite true.
The "title" of a submission is part of the submission the submission itself being the work. As long as the work is sufficiently substantive then copyright will protect it as a whole.
The linked document refers to things like the title of a book wherein you wish to use the title separately to refer to the work. An author can't claim that you infringed their copyright simply because you referred to their work. This is not the situation at hand. HN is not merely using the title it is altering it and presenting it as the substantial part of the complete work that it indeed is. If you think about it you'll see how untenable your limited interpretation is, under your interpretation I can take a Harry Potter work and retitle it and add my name as author because all I've altered is the title and name ... to recap it is a particular use of the title that your link refers to and not to modifying without license.
Now, arguably in the listings of stories HN could write a new title but on the page when presenting the submitted work they would still lack license to present the work modified (ie with their title).
HN should either reject the work as a submission, retract the work or seek a license to modify it. The simplest thing would be to just add some boilerplate that says "by submitting content we reserve the right to alter it for editorial purposes". Though it would be nice to allow the user to choose to retract the story or allow it as edited.
There may well be a fair use argument for content created in the USA. I doubt there is for content created by European users.²
FWIW altering a title could also cause defamation or be an act of libel but such situations are relatively unlikely. Modification of a substantial part of a copyright work without a license is infringing already. IANA(IP)L but arguing that a HN submission¹ is a work for copyright purposes seems pretty straight forward.
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¹ that's not machine generated or particular short so as to lack discreteness or substance enough to qualify for being a work.
² I've not seen enough case law on internet content to determine how location of created content is judged; is content created via your form considered to be created where I am, where your company resides, where your servers are or what.
That's not quite true.
The "title" of a submission is part of the submission the submission itself being the work. As long as the work is sufficiently substantive then copyright will protect it as a whole.
The linked document refers to things like the title of a book wherein you wish to use the title separately to refer to the work. An author can't claim that you infringed their copyright simply because you referred to their work. This is not the situation at hand. HN is not merely using the title it is altering it and presenting it as the substantial part of the complete work that it indeed is. If you think about it you'll see how untenable your limited interpretation is, under your interpretation I can take a Harry Potter work and retitle it and add my name as author because all I've altered is the title and name ... to recap it is a particular use of the title that your link refers to and not to modifying without license.
Now, arguably in the listings of stories HN could write a new title but on the page when presenting the submitted work they would still lack license to present the work modified (ie with their title).
HN should either reject the work as a submission, retract the work or seek a license to modify it. The simplest thing would be to just add some boilerplate that says "by submitting content we reserve the right to alter it for editorial purposes". Though it would be nice to allow the user to choose to retract the story or allow it as edited.
There may well be a fair use argument for content created in the USA. I doubt there is for content created by European users.²
FWIW altering a title could also cause defamation or be an act of libel but such situations are relatively unlikely. Modification of a substantial part of a copyright work without a license is infringing already. IANA(IP)L but arguing that a HN submission¹ is a work for copyright purposes seems pretty straight forward.
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¹ that's not machine generated or particular short so as to lack discreteness or substance enough to qualify for being a work.
² I've not seen enough case law on internet content to determine how location of created content is judged; is content created via your form considered to be created where I am, where your company resides, where your servers are or what.