The Health Care Institution (HCI) maintained a no-solicitation rule, which, on its face, prohibits solicitation for any purpose during working time and in immediate patient care areas. Before and after the union’s organizing campaign began, HCI was inconsistent with its enforcement of this policy. For example, the employer warned and/or disciplined employees engaged in union solicitation activity. But it allowed institutional commercial solicitations (sales of Avon, Mary Kay cosmetics, Tupperware, and Pampered Chef products), individual commercial solicitations (sales of homemade foods, jewelry, and holiday crafts), school fund-raising solicitations (sales of candy, candles, and wrapping paper items), and personal solicitations (collection of money for various families). HCI believes that under the Register Guard rule, because it did not permit communications of a character similar to union organizing, it lawfully enforced its rule against employees engaged in union solicitation activity. The union disagreed. Decide. [Office of General Counsel, Register Guard cases, Case No. 2 DLR No. 97, E-6 (May 20, 2008)]