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.
In ARO, Inc. v. NLRB, 596 F.2d 713, 718 (6th Cir. 1979), this court held, "For an individual claim or complaint to amount to concerted action under the Act it must... be made with the object of inducing or preparing for group action...."
Finding concerted activity because "a reasonable inference can be drawn that the men involved considered that they had a grievance and decided, among themselves, that they would take it up with management"
In Taylor an employee who mentioned to the classifier that one of the foremen was working and thereby stealing work from the other employees in the department was discharged the next day.