This will apply to the ones who think they've given their rights to the JOURNAL rather than their first master, the NIH who funded their research. Or not necessarily the authors personally, but perhaps their institutions, who might be under a different impression of rights to the work.
The Elseviers of the world have gotten to the fruits of scientific labors years and years ago. It's only now that people have woken up and started to complain that the results of publicly funded research are getting paywalled into private hands. After, what? 50 years of this? At least it's a step.