3-2. Fair Use Doctrine. Jonathan Caven-Atack had been a member of the Church of Scientology for nine years when he decided that the church was a dangerous cult and its leader, L. Ron Hubbard, a vindictive and profoundly disturbed man. CavenAtack spent the next several years investigating, and then writing a book about, Hubbard and the church. Caven-Atack's purpose was to expose what he believed was the pernicious nature of the church and the deceit upon which its teachings were based. Approximately 3 percent of Caven-Atack's book consisted of quotations from Hubbard's published works. When New Era Publications International, which held exclusive copyright rights in all of Hubbard's works, learned that the Carol Publishing Group planned to publish CavenAtack's book, it sued Carol Publishing for copyright