The National Labor Relations Act's limitations on employer no-solicitation/no-distribution policies have been established for decades, right? Most labor relations practitioners and Human Resources specialists are familiar with "black letter law" that workplace solicitation can be restricted to non-work time and distribution can be restricted to non-work time and non-work areas. Simple, isn't it? Under two recent NLRB cases, Conagra Foods, Inc. , 361 N.L.R.B. No.