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n.3. See also, Boltuch, Workplace Closures and Company Reorganizations: Enforcing N.L.R.B., Contract and Noncontract Claims and Obligations, 7 Labor Law 53, 78 (1991) (characterizing contract claims arising from collective bargaining agreements against a successor as "a total waste of time").
3 See NLRB v. Burns Int'l Security Servs., 406 U.S. 272, 284, 294-95 (1972); Bellingham Frozen Foods, Inc. v. NLRB, 626 F.2d 674, 678-79 (9th Cir. 1980).
4 See Sullivan Industries v. NLRB, 957 F.2d 890, 897 (D.C. Cir. 1992).
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