I would probably hesitate to call the Orcs a 'creation' of Morgoth. I have a feeling that the Professor would feel the same way; he might, however, be comfortable calling them a sub-creation. For Tolkien, 'creation' per se was specifically creatio ex nihilo, creation from nothing, a power which only Eru/God has. All any of the Ainur can do is creatio ex paleo, creation from existing matter, as evidenced by Aulë's creation of the Dwarves.
Just my two cents, for all they're worth. And, by the way, it's nice to be back on the Downs!
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Agannâlô burôda nênud; zâira nênud.
Adûn izindi batân tâidô ayadda: îdô kâtha batîna lôkhî.
Êphalak îdôn Yôzâyan. Êphal êphalak îdôn hi-Akallabêth.
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