Holding that protection from retaliation for "fil[ing] charges or giv[ing] testimony" under the National Labor Relations Act extends to an employee who gave a written sworn statement to an NLRB examiner
In NLRB v. Interboro Contractors, Inc., 388 F.2d 495, 500 (2d Cir. 1967), the Court of Appeals for the Second Circuit stated that the efforts of an individual employee acting alone to enforce the provisions of a collective bargaining agreement may be deemed "concerted," and thus protected, at least when the individual's interpretation of the agreement has a reasonable basis.