In Cott, the Board, on the authority of NLRB v. Gissel Packing Co., 395 U.S. 575, 89 S.Ct. 1918, 23 L.Ed.2d 547 (1969), entered an order directing the predecessor employer to bargain with the union on the basis of a card majority because, in the Board's determination, the predecessor's unfair labor practices had made a fair election in the unit unlikely.