In Reliance Fuel Oil Corp., the Board found that Reliance Fuel Oil Corp. ("Reliance"), a New York corporation engaged in the business of selling fuel oil for heating purposes and servicing oil burners and boilers, was engaged in commerce within the meaning of the NLRA because it had "purchased a substantial amount of fuel oil from Gulf, a company concededly engaged in interstate commerce."
In Armstrong Cork Co. v. NLRB, 211 F.2d 843 (5th Cir. 1954), an employer announced to an assembly of workers shortly after a representation election that he intended to remove a "pledge" which the Company had posted on the bulletin board setting forth employees' rights.