Eric Berne of a heart attack in Carmel on July 15, 1970. Eric Berne Eric Berne (May 10, 1910 – July 15, 1970) was a Canadian-born psychiatrist who, in the middle of the 20th century, created the theory of transactional analysis as a way of explaining human behavior. Berne’s theory of transactional analysis was based on the ideas of Freud but was distinctly different. Freudian psychotherapists focused on talk therapy as a way of gaining insight to their patient’s personalities. Berne believed that insight could be better discovered by analyzing patients’ social transactions. Berne was among the first psychiatrists to apply game
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