Editing NXIVM (section)

==== Cult allegations in early 2000s ====
{{Main|NXIVM Corp. v. Ross Institute}}
NXIVM claimed its training was a [[trade secret]], subject to [[non-disclosure agreements]], but reportedly used a technique the organization called "rational inquiry" to facilitate personal and professional development. In 2003, NXIVM sued the Ross Institute in the case known as ''[[NXIVM Corp. v. Ross Institute]]'', alleging [[copyright infringement]] for publishing excerpts of content from its manual in three critical articles commissioned by cult investigator [[Rick Alan Ross]] and posted on his website.<ref name=Hochman>{{citation |title=A Forensic Psychiatrist Evaluates ESP |date=February 2003 |publisher=Cult Education Institute |url=https://culteducation.com/group/907-nxivm/6047-a-forensic-psychiatrist-evaluates-esp.html}}</ref><ref name=Martin1>{{citation |title=A Critical Analysis of the Executive Success Programs Inc. |date=February 2003 |publisher=Cult Education Institute |url=https://culteducation.com/group/907-nxivm/5969-a-critical-analysis-of-the-executive-success-programs-inc.html}}</ref><ref name=Martin2>{{citation |title= Robert Jay Lifton's eight criteria of thought reform as applied to the Executive Success Programs |date=February 2003 |publisher=Cult Education Institute |url= https://culteducation.com/group/907-nxivm/5980-robert-jay-liftons-eight-criteria-of-thought-reform-as-applied-to-the-executive-success-programs.html}}</ref> Ross posted a psychiatrist's assessment of NXIVM's "secret" manual on his website that called the regimen "expensive [[brainwashing]]".<ref name="Kohler"/><ref name="auto6">{{cite web |title=NXIVM Corp. v. Ross |url=http://www.citmedialaw.org/threats/nxivm-corp-v-ross |work=legal case |publisher=Citizen media law company |access-date=February 10, 2012}}</ref>

Ross obtained the manual from former member Stephanie Franco, a co-[[defendant]] in the trial, who had signed a [[non-disclosure agreement]] not to divulge information from the manual to others. NXIVM filed suits in New York and New Jersey, but both were dismissed.<ref name="Kohler"/><ref name="auto6"/> On appeal, the [[United States Court of Appeals for the Second Circuit]] affirmed the dismissal, ruling that the defendant's critical analysis was [[fair use]] since the secondary use was [[transformative]] as criticism and was not a potential replacement for the original on the market.<ref name="Casenotes2007">{{cite book|author=Aspen Publishers|title=Copyright. Keyed to Keyed to Course Using Gorman and Ginsburg's Copyright: Cases and Materials Seventh Edition|url=https://books.google.com/books?id=I6gWONBoXpIC&pg=PA95|year=2007|publisher=Wolters Kluwer|isbn=978-0735561762|pages=95–96|series=Casenote Legal Briefs}}</ref><ref name="MeinersRingleb2006">{{cite book|author1=Roger E. Meiners|author2=Al H. Ringleb|author3=Frances L. Edwards|title=The legal environment of business|url=https://books.google.com/books?id=8ZvaVXT1n3IC&pg=PA230|year=2006|publisher=Cengage Learning|isbn=978-0324204858|page=230}}</ref><ref name=justia>{{cite court |litigants=NXIVM Corp. v. Ross Institute|reporter=F.3d |opinion=471 |court=2d Cir. |date=2004 |url=https://law.justia.com/cases/federal/appellate-courts/F3/364/471/532988/ |access-date=February 24, 2018 }}</ref>

In October 2003, ''[[Forbes]]'' published a critical article on NXIVM and Raniere.<ref name="Forbes20031013"/> According to ''[[Vanity Fair (magazine)|Vanity Fair]],'' NXIVM leadership, who had spoken to ''Forbes'', had expected a positive story. They were especially upset by remarks made by Bronfman, who told ''Forbes'' that he believed NXIVM was a cult and that he was troubled by his daughters' "emotional and financial investment" in it.<ref name="Forbes20031013"/> In 2006, ''Forbes'' published an article about the Bronfman sisters, stating that they had taken out a [[line of credit]] to loan NXIVM $2&nbsp;million, repayable through personal training sessions and phone consultations with Salzman.<ref name= "Forbes20060724">{{cite news |url=https://www.forbes.com/forbes/2006/0724/044a.html |title=The Bronfmans and the Cult |last1=Berman |first1=Phyllis |date=June 24, 2006 |work=Forbes |access-date=July 24, 2006 |last2=Gillies |first2=Andrew T. |last3=Novack |first3= Janet |last4=Egan |first4=Mary Ellen |last5=Blakeley |first5=Kiri}}</ref> Another ''Forbes'' article in 2010 discussed the failures of commodities and real estate deals by the Bronfmans made on Raniere's advice.<ref name="Forbes20100329">{{cite web |url= https://www.forbes.com/sites/docket/2010/03/29/the-bronfmans-and-the-cult/ |title=The Bronfmans and The 'Cult' |last=Vardi |first=Nathan |date= March 29, 2010 |work=Forbes |access-date= February 11, 2018}}</ref>