One of the key holdings by the Bush Board in 2007 which drew withering fire from unions was the decision in Dana Corp.criticizing neutrality agreements calling for union recognition based on card checks.  The Bush Board took great pains to underscore its strong support for secret ballot elections over union authorization cards.  In fact, the Board ordered that a process be implemented requiring employers to post written notices of such voluntary recognitions in order to provide employees an adequate opportunity to file timely decertification petitions should they disagree with the employers’ actions.  On December 6, 2010, the Obama Board reversed direction and upheld the lawfulness of such a card check procedure involving Dana Corp.