Many years before 2002, IUEC entered into a series of collective agreements with the National Elevator Industry, Inc. (“NEII”), a multi-employer bargaining group to which kone was a member. (Amend. Compl. In 2002, KONE withdrew from NEII for collective bargaining reasons and negotiated its own collective agreement with the IUEC, lasting between 9 July 2002 and 8 July 2007 (“KONE agreement”). (Id. 19)) In 2007, NEBA negotiated, on behalf of KONE and other members of employers, on behalf of its local affiliated unions, a collective agreement with the IUEC, lasting between 9 July 2007 and 8 July 2012 (“NEBA agreement”). (Id. 20)) We need new members to establish the collective agreement in a larger number of companies. The collective agreement is a minimum and serves as a model, but as a general rule, companies have better agreements on the spot! The conduct that led to the action was the alleged unlawful termination of work by members of Local 5, 7 and 10, which took place on April 16, 2008. The narrow geographic scope of the work stoppage is important. While KONE and IUEC operate in the United States, the strike has affected only parts of several Central Atlantic states, including New Jersey, Delaware, Pennsylvania, Maryland, Virginia and Washington, D.C. (Amend.
The complainants claim that the work stoppage was encouraged by the suspension of four 10 local elevators and was designed to put pressure on KONE in Maryland. (Id. 40; Pls. `Opp`n 13.) In addition, the IUEC and its local chapters carried out their strike in an organized and concerted manner. On April 16, 2008, premises 5, 7 and 10 left their sites simultaneously without authorization. (Amend. Compl. The applicants contend that the Maryland-based IUEC adopted a directive to local 5, 7 and 10 members that ordered the strike in response to the suspensions. (Id.
40.) The National Elevator Bargaining Association (“NEBA”) and KONE, Inc. (`KONE`) (including the “applicants”) sued this court under the Labor Management Relations Act (“LMRA”), 29 U.S.C.