In Lockheed Martin Skunk Works, a Division of Lockheed Martin Corp., 331 N.L.R.B. 852 (N.L.R.B. 2000), the National Labor Relations Board (NLRB) considered whether a representation election should be set aside as a result of the employees distributing anti-union information using the company email system, where the union had requested and was granted access to the company email system to distribute its pro-union information.
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