 The Court also held that only the representative of the workers (the union) could issue collective bargaining proposals under the law, and that proposals transmitted by a third party did not trigger the Act's protections or duties.Columbian Enameling & Stamping Co. manufactured metal utensils in Terre Haute, Indiana.It recognized a labor union of its employees and signed a one-year collective bargaining agreement on July 14, 1934, which provided for arbitration of disputes and barred work stoppages (pending arbitration).