| | Gibbons, Del Deo, Dolan, Griffinger & Vecchione (Site not responding. Last check: 2007-10-22) |
 | | The majority found that the Union's secondary conduct in picketing the United Way and in encouraging the public to stop supporting the United Way until it stopped funding the VNHS did not violate Section 8(b)(4)(ii)(B) of the Act. |
 | | The Board's decision, however, permits a Union to engage in secondary conduct intended to force the primary employer to capitulate even while a challenge is pending. |
 | | Employers seeking to challenge a certification of representative issued by the Board should take heed that they are not protected from secondary activity by the Union pending the challenge so long as the Union's conduct post-dates the certification of representative and is intended to force the employer to recognize and bargain with the Union. |
| www.gibbonslaw.com /publications/articlesuser2.cfm?pubid=491 (729 words) |