In three recent memos to its Regional Offices, the NLRB Division of Advice concluded employee Facebook postings about their employment may not be protected from disciplinary action even if the complaints are job related. Associate General Counsel Barry Kearney concluded in each case that the online comments were individual grievances rather than protected concerted activity. Acting General Counsel Lafe Solomon followed up with a memorandum summarizing all of the NLRB social media/protected concerted activity cases from the past year, including the three discussed by Kearney.