The NLRB’s Division of Advice found in Tasker Healthcare Grp. d/b/a Skinsmart Dermatology (4-CA-94222, 5/8/2013) that an employer did not violate the NLRA when it discharged the charging party for critical or derogatory comments made about her employer and supervisors during a Facebook conversation with other employees.  According to the NLRB memorandum, the charging party’s comments “bemoaned the return of a former employee and stated that her current supervisor tried to tell her something and she told her to ‘back the freak off’; that the Employer was ‘full of sh[*]t’; and that the Employer should ‘FIRE ME…Make my day.’”  Distinguishing a number of prior NLRB memoranda and decisions, the Division of Advice found that the charging party’s Facebook comments “merely expressed an individual gripe rather than any shared concerns about working conditions”, and thus did not constitute concerted activity.  The Division of Advice reasoned that the charging party’s Facebook comments “reflected her personal contempt for her returning coworker and for her supervisor, rather than any shared employee concerns over terms and conditions of employment.”  Although noting that one co-worker expressed some support for the charging party (that “it’s getting bad there[,] it’s just annoying as hell”), the Division of Advice concluded that there was no evidence that any of the employees interpreted the charging party’s comments “as an expression of any shared concerns about working conditions.”  Accordingly, the Division of Advice recommended dismissing the unfair labor practice charge.