Technology for instance in the form of e-mail is important in the organizing process. However, preventing union employers form sending pro-union e-mail messages on company e-mail is easier said that done. Prohibiting only union e-mail messages on company e-mail is easier said than done. Prohibiting only union’s e-mail violate NLRB decisions. And instituting a rule barring workers from using e-mail for all non work related topics may also be futile if the company actually does little to stop e-mail other than pro-union messages.