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. Caven-Atack 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 Caven-Atack s book, it sued Carol Publishing for copyright infringement. Carol Publishing claimed that Caven-Atack s use of Hubbard s works was a fair use of the copyrighted materials. What 

factors must the court consider in making its decision? What will its

decision be? Discuss.