Eric Berne a demanding pace of research, teaching in addition. He took an appointment in 1950 as Assistant Psychiatrist at Mt. Zion Hospital, San Francisco, and simultaneously began serving as a Consultant to the Surgeon General of the US Army. In 1951, he accepted a position of Adjunct and Attending Psychiatrist at the Veterans Administration and Mental Hygiene Clinic, San Francisco. The years from 1964 to 1970 were restless ones for Berne. His personal life became chaotic and he focused on his writing. Berne created the theory of transactional analysis as a way to explain human behavior . Berne’s theory was based
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,