The National Labor Relations Board recently held that union members have the right to engage in "bannering," displaying large banners at a secondary employer's worksite to publicize a labor dispute with a primary employer and attempting to "influence" the secondary employer. These banners are stationary and held by union members at the entrances of a secondary employer's worksite, and they carry messages directed at the neutral, otherwise uninvolved employer in the dispute with the union, such as "Shame on [ABC Corporation]." In Southwest Regional Council of Carpenters (New Star General Contractors, Inc.), the Board ruled that union bannering at secondary employers' worksites did not violate the National Labor Relations Act because the banners did not constitute picketing and did not otherwise constitute threats, coercion, or restraint prohibited by the Act. The Board has concluded that "the banner displays did not constitute picketing because they lacked the 'element of confrontation [that] has long been central to our conception of picketing for purposes of the Act's prohibition.'" The banner displays in New Star were viewed as not involving the "core" conduct of "traditional" picketing, such as carrying picket signs and patrolling. This Board believes that requiring employees of a neutral employer to walk past a large banner saying "shame on" their employer is not confrontational even though requiring the same employees to walk past picket lines with signs carrying the same message would be confrontational. This decision continues the pattern established by the new Board to expand the ability of unions to engage in activities previously prohibited by Board decisions. Unless the appellate courts reverse the Board decision in New Star, employers can expect an increase in union bannering activity.