Religious Technology Ctr. v. Lerma
United States District Court for the Eastern District of Virginia
40 U.S.P.Q.2d 1569 (1989)
Lerma (defendant) posted online substantial portions, with little commentary, of the Church of Scientology's confidential Operating Thetan Documents (OTDs), over which the Religious Technology Center (RTC) (plaintiff) held copyright. The Church strictly limited who could access the OTDs, kept them in guarded vaults, and required nondisclosure agreements from anyone who saw them. RTC sued Lerma for copyright infringement.
Whether a third party may freely use a copyrighted work under the fair-use doctrine, which weighs the purpose and character of the use, the nature of the copyrighted work, the amount used relative to the whole, and the effect on the market for the original.