At a time when the labor movement is working to increase its ranks, unions are increasingly relying on e-mail and web pages to spread their message and organize new members. While an employer’s ability to monitor traditional methods of communication ? print and oral ? and in-person solicitation has been the subject of numerous National Labor Relations Board (?NLRB? or ?Board?) decisions, until now the Board had not addressed the rules regulating electronic workplace conduct vis a vis the National Labor Relations Act (the ?Act?).