Eric Berne on the ideas of Freud but were distinctly different. Freudian psychotherapists focused on patient’s personalities. Berne believed that insight could be better discovered by analyzing patients’ social transactions. Berne mapped interpersonal relationships to three ego-states of the individuals involved: the "Parent, Adult," and "Child" state. He then investigated communications between individuals based on the current state of each. He called these interpersonal interactions "transactions" and used the label "games" to refer to certain patterns of transactions which popped up repeatedly in everyday life. The origins of transactional analysis can be traced to the first five of Berne’s six articles on
Berne Convention and attorney's fees only available for registered works. However, in "Moberg v Leygues", a 2009 decision of a Delaware Federal District Court, decided that the protections of the Berne Convention are supposed to essentially be "frictionless," meaning no registration requirements can be imposed on a work from a different Berne member country. This means Berne member countries can require works originating in their own country to be registered and/or deposited, but cannot require these formalities of works from other Berne member countries. Under Article 3, the protection of the Convention applies to nationals and residents of countries that are party