But cf. New Era Publications International v. Carol Publishing Group, 904 F.2d 152 (2nd Cir. 1990). A federal appeals court ruled that the use of several extended quotations of a religious leader reproduced without permission in an uncomplimentary biography constituted fair use. The court evaluated each of the 4 “fair use factors” and concluded that all of them supported the finding of fair use. With regard to the first factor, the court concluded that biographies, and particularly critical biographies, generally constitute fair use. The proposed book used quotations from the religious leader's published writings “for the entirely legitimate purpose of making his point that [the leader] was a charlatan and his church a dangerous cult.” While the author no doubt expected to make a profit, this was a secondary purpose. As to the second factor, the court again emphasized that the proposed book was a biography, and that biographies generally constitute fair use. The court observed that “biographies, of course, are fundamentally personal histories and it is both reasonable and customary for biographers to refer to and utilize earlier works dealing with the subject of the work and occasionally to quote directly from such works.” The third fair use factor asks how much of the copyrighted work is quoted—both in terms of quantity and quality. The court concluded that only small portions of several works were quoted, rather than larger selections of any one work. Further, the portions quoted were not “key portions” of any of the books. Finally, the court concluded that the fourth factor led to a finding of fair use, since the biography would have little if any impact on the sale of the copyrighted works.