In N.L.R.B. v. International Ass'n of Machinists, 9 Cir., 263 F.2d 796, 799, it was held that the actions of a union in listing an employer on its "'We Do Not Patronize' list" and in urging others not to do business with him were protected by the First Amendment and did not constitute unfair labor practice.
In Schultz v. National Labor Relations Bd., 284 F.2d 254 (D.C. Cir. 1960), the court discussed the legislative history of 29 U.S.C. ยง 152(5), opining that the decision of Congress to omit the word "individual" from the definition of "labor organization" indicated a clear intention to exclude the individual from this broad definition altogether.