The following comments are submitted regarding the Board’s Proposed Rule on the filing and processing of petitions relating to union representation of employees for purposes of collective bargaining (“Proposed Rule”). The Proposed Rule was published in the Federal Register on June 22, 2011. See 76 Fed. Reg. 36,812-36,847 (2011).

These comments are submitted on behalf of the Coalition for a Democratic Workplace (“CDW” or the “Coalition”). CDW encompasses hundreds of employer associations, individual employers and other organizations that collectively represent millions of businesses of all sizes. They employ tens of millions of individuals working in every industry and every region of the United States. These employers and employees have a profound interest in the Board’s Proposed Rule, which the Coalition believes is contrary to many provisions, policies and purposes of the National Labor Relations Act, 29 U.S.C. §§ 151 et seq. (“NLRA” or “Act”) and inconsistent with the free speech protection afforded by the United States Constitution.