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In Newspaper Guild v. NLRB, the Court of Appeals for the District of Columbia Circuit held that collective bargaining was not mandatory on all aspects of a newspaper's Ethics Code and Office Rules. The court also held that the penalty provisions attached to these rules could not be separated from the substantive provisions that they were designed to enforce: both were either mandatorily bargainable or they were not. This decision is the most recent one reported that considers the applicability of the National Labor Relations Act' (NLRA) to a newspaper in light of the newspaper's assertion of its first amendment rights.