In United Steelworkers, the Court warned that the NLRA "does not command that labor organizations as a matter of abstract law, under all circumstances, be protected in the use of every possible means of reaching the minds of individual workers, nor that they are entitled to use a medium of communication simply because the employer is using it."
In NLRB v. United Aircraft Corp., 324 F.2d 128 (2d Cir. 1963), cert. denied 376 U.S. 951, 84 S.Ct. 969 (1964), the company rule prohibited distribution of union literature in nonworking areas of the company's premises.
In Montgomery Ward, for instance, the court modified an order that applied to all the company's plants because there was "no evidence presented... of any national pattern of unfair labor practices."