15.  By Spring 2020, the novel coronavirus SARS-CoV-2, which can cause the disease  COVID-19, spread rapidly around the world.   17.  Since that time, at least three separate COVID-19 vaccines have been developed  and authorized for use in the United States.  The Food and Drug Administration (“FDA”) issued  an Emergency Use Authorization (“EUA”) for the Pfizer-BioNTech vaccine on December 1, 2020.   One week later, the FDA issued a second EUA for the Moderna COVID-19 vaccine.  Finally, the  FDA issued an EUA for the Johnson & Johnson COVID-19 vaccine on February 27, 2021.     18.  On August 23, 2021, the FDA issued full approval for the Pfizer vaccine Comirnaty  for individuals 16 years of age and older.  Pfizer’s EUA also remains in place.   19.  To date, the FDA has not yet issued any other approvals for either the Moderna or  Johnson & Johnson vaccine.  B.  United’s Vaccine Mandate   20.  On August 6, 2021, United’s Chief Executive Officer (“CEO”) Scott Kirby  announced that all employees would be required to receive a COVID-19 vaccine within five weeks  of the FDA granting full approval of a vaccine, or five weeks after September 20, 2021, whichever  came first.      21.  As noted, the FDA approved Pfizer’s COVID-19 Comirnaty vaccine on August 23,  2021.     23.  Employees are required to upload a copy of their vaccination record to a United  database called Flying Together by September 27, 2021.  See Thomas Pallini, United is the first  US airline to require all employees be vaccinated against COVID-19, BUSINESS INSIDER (Aug. 6,  2021),  https://www.businessinsider.com/united-requiring-us-employees-get-covid-19-vaccine- 2021-8.   24.  Employees who do not upload a copy of their vaccination record showing a  COVID-19 vaccination will be terminated.     25.  United’s mandate is absolute—there is no alternative for periodic testing, mask  wearing, or social distancing, even for employees who have already had COVID-19 and still enjoy  immunity from the disease.  Employees must choose vaccination or termination.  Or, as discussed  below, employees who are “accommodated” for religious or health reasons may choose what will  likely be several years of unpaid leave without benefits: effectively, termination.   26.  This policy from United contrasts with the Federal Government’s recent  announcement that the Department of Labor is developing a rule to require certain large employers  to mandate vaccination or periodic testing for its employees.  United is not offering the option of  periodic testing, either in general or for employees who receive an accommodation.   28.  When United announced the vaccine mandate, it stated that employees could  request accommodations for religious or health reasons.  See Daniella Genovese, United Airlines  vaccine mandate driven by delta variant, hospitalization data, CEO Scott Kirby says,  FOXBUSINESS (Aug. 10, 2021), https://www.foxbusiness.com/lifestyle/united-ceo-scott-kirby- pushed-vaccine-mandate-driven-by-hospitalization-data.  This is in line with Equal Employment  Opportunity Commission (“EEOC”) guidance on private employers issuing such mandates.  See  What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO  Laws §§ K.1 & K.2., EEOC (May 28, 2021), https://www.eeoc.gov/wysk/what-you-should-know- about-covid-19-and-ada-rehabilitation-act-and-other-eeo-laws.   29.  However, United’s CEO Mr. Kirby also threatened employees “to be very careful  about” requesting such accommodations.  Mr. Kirby stated that there would be very “few people  that get through the medical and religious exemption process”—describing such employees  derisively as “all [of a] sudden decid[ing] ‘I’m really religious.’”  Mr. Kirby threatened those  employees by stating that they are “putting [their] job[s] on the line” if they request such  accommodations.  See Decl. of Kimberly Hamilton, attached to Plaintiffs’ Motion for a Temporary  Restraining Order and Preliminary Injunction.       30.  In addition to Mr. Kirby’s threats, United has placed substantial and unconscionable  pressure on its employees.  One of the many examples of such pressure, some of which are more  specifically discussed below, occurred in early-September when United began sending postcards  to all employees who had not yet provided proof of vaccination.     32.  According to United, this vaccination mandate is aimed at increased safety.  See  Leslie Josephs, United will require its U.S. employees to be vaccinated, a first for country’s major  airlines, CNBC (Aug. 6, 2021), https://www.cnbc.com/2021/08/06/united-airlines-vaccine- mandate-employees.html.  Yet United does not require any passenger flying on its planes, or  interacting with its staff, to be vaccinated.  See David Koenig, United Airlines will require US  employees to be vaccinated, AP NEWS (Aug. 6, 2021), https://apnews.com/article/united-airlines- vaccine-mandate-employees-frontier-e8eef8e8f11d4924b81768484e5401a1.  Nor does it require  its employees from other countries to be vaccinated, even though those employees work and come  in contact with United crews from the United States.  Id.  The mandate does not apply to regional  airline partners that fly United customers on shorter routes that feed United’s mainlines.  See  Josephs, supra ¶ 32.  And the mandate does not apply to pilots from other airlines allowed to ride  in the “jumpseat” of the aircraft (in the cockpit) with United flight officers.  See Jumpseat  Committee  Update,  A.  The COVID-19 Pandemic and Response  