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Purple Communications, Inc.

National Labor Relations Board
361 N.L.R.B. 126 (2014)


Purple Communications, Inc. (Purple) (defendant) provided employees with access to its email system and assigned each an individual email account. However, Purple’s electronic communication policy strictly prohibited using the email system for non-work-related activities or sending unsolicited personal email. A union that organized Purple’s employees (plaintiff) challenged election results on the ground that the electronic communications policy interfered with the employees’ rights, making it an unfair labor practice under the National Labor Relations Act (NLRA). The judge found the policy lawful under the standard set by Register Guard, 351 NLRB 1110 (2007), and the National Labor Relations Board (NLRB) reviewed the decision.

Rule of Law


Holding and Reasoning (Pearce, Chairman)

Dissent (Johnson, Member)

Dissent (Miscimarra, Member)

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