context: The Board has argued that giving effect to the arbitrator's decision in this case would run afoul of the principle that waivers of employee rights must be undertaken in "clear and unmistakable" terms.
citation_a.signal: but cf.
citation_a.identifier: 663 F.2d 455, 458-59
citation_a.parenthetical: clear and unmistakable waiver of right to strike over administration of pension fund held unnecessary where general contract term extended scope of no-strike clause beyond scope of arbitration clause
citation_a.sentence: But cf. Pacemaker Yacht Co. v. NLRB, 663 F.2d 455, 458-59 (3d Cir. 1981) (clear and unmistakable waiver of right to strike over administration of pension fund held unnecessary where general contract term extended scope of no-strike clause beyond scope of arbitration clause).
citation_b.signal: cf.
citation_b.parenthetical: absent explicit waiver of right to strike in protest of employer's unfair labor practices, such right is not waived
citation_b.sentence: Cf. Mastro Plastics Corp. v. NLRB, 350 U.S. 270, 281-83, 76 S.Ct. 349, 357-358, 100 L.Ed. 309 (1956) (absent explicit waiver of right to strike in protest of employer’s unfair labor practices, such right is not waived).