Eric Berne Cyprian St. Cyr ("Cyprian Sincere") in whimsical articles in the "Transactional Analysis Bulletin". Berne was married three times. His first wife was Elinor McRae. They married in 1942, had two children, and divorced acrimoniously in 1945. In 1949 he married Dorothy DeMass Way, with whom he also had two children before their divorce in 1964. After his popular success, Eric married a third time, to Torre Peterson in 1967. The couple took up residence in Carmel, California, where he wrote, but he continued some clinical work in San Francisco. This marriage also ended in divorce, in early 1970. Berne died
Berne Convention exceptions, the Berne Convention establishes the "three-step test" in Article 9(2), which establishes a framework for member nations to develop their own national exceptions. The three-step test establishes three requirements: that the legislation be limited to certain (1) special cases; (2) that the exception does not conflict with a normal exploitation of the work, and (c) that the exception does not unreasonably prejudice the legitimate interests of the author. The Berne Convention does not expressly reference doctrines such as fair use or fair dealing, leading some critics of fair use to argue that fair use violates the Berne Convention. However,