15.  Defendant Strom, a privately-held corporation, provides staffing in the form of  strike and lockout replacement labor for unionized employers at locations throughout the United  States.   17.  In doing so, these strike-busting agencies and the companies that hire them not only  exert downward pressure on working standards, benefits, and conditions for workers in general,  but do so on the backs of temporary workers who are uniquely vulnerable to exploitation and  limited in their ability to organize or advocate for their rights.2   18.  Although there has been a long history of employers hiring replacement workers to  oppose union organizing, the scale of worker replacement afforded by strike-busting agencies like  Strom takes this anti-union tool to an entirely new level.3 Strike-busting agencies are able to  mobilize hundreds or thousands of skilled or semi-skilled workers with little to no notice, lowering  the hurdles for employers taking hardline stands against union demands and eliminating any  negative implications to a company’s productivity.   19.  These features are central to the services Strom offers, which are advertised as  calling upon a “30,000+ employee database to identify Strom employees with project-relevant  experience,” “eliminate[ing] the lead-time generally associated with the activation of temporary  replacement workers”, and ensuring that Strom demonstrates “to union leaders that direct action  is being taken to make sure all company obligations are met without exception.”  http://www.stromengineering.com/staffing/strike-staffing/ (last accessed June 30, 2017).   21.  Strom describes an employer’s motivations during a lockout as follows:   Other times, particularly in the United States, a lockout occurs when union  membership rejects the company’s final offer at negotiations and offers to return to  work under the same conditions of employment as existed under the now-expired  contract. In such a case, the lockout is designed to pressure the workers into  accepting the terms of the company’s last offer.  http://stromengineering.rocket55staging.com/about/resources/ (last accessed June 30, 2017)  (emphasis added).   22.  Touting its position as “the nation’s most reputable industrial strike staffing  company” with over “55 years of experience in labor staffing and 25 years of experience providing  strike staffing,” Strom’s promotional statements hint at the larger historical context within which  Strom’s activities and those of the companies with whom it contracts should be understood.   http://www.stromengineering.com/about/about-strom/ (last accessed June 29, 2017).   24.  Meanwhile, the structure of strike-busting agencies’ employment of replacement  workers places those workers in a uniquely precarious position that makes it nearly impossible for  them to organize and advocate for their own labor rights.5   25.  While strike-busting agencies employ thousands of replacement workers, these  workers do not work together consistently but are sent from workplace to workplace, isolated from  both their replacement and union counterparts and thus limited in their ability to organize and  advocate for themselves.   26.  Even if they are stationed at one worksite for an extended period, few replacement  workers can risk engaging in union activities or other advocacy because they could immediately  lose their current job as well as any future assignments by being identified as trouble-makers. As  such, the structural ambiguity of temporary employment places logistical limitations on traditional  labor protections.   27.  With neither job security, the ability to organize, nor ready access to traditional  labor protections, replacement workers are extremely vulnerable. They are at the mercy of the  strike-busting agencies and companies whose priorities center on ensuring continuity in their own  operations, frequently at the expense of the work conditions and basic rights of the replacement  workers that make this possible.  B.  A.  BACKGROUND   