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Groom Style
What the groom wears on the wedding day should speak to his personal sense of style and the overall aesthetic of the day. Whether you want to wear a suit or a tuxedo, need advice on cuts and colors, or want help finding the right accessories, we'll help you choose your ideal look.
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text: HomeIndie GameAvaruustaistelupeli (ATP) - an area fight recreation Indie Game Avaruustaistelupeli (ATP) – an area fight recreation By Team FunTrove November 23, 2022 0 1 Share FacebookTwitterPinterestWhatsApp mobilelast Despite the sluggish begin, this week ended up fairly productive. I began designing and implementing a brand new audio background which has no direct impact on the gameplay, however which undoubtedly provides temper. Below is an audio clip from the ship choice, participant introduction, countdown and battle. I've discovered it helpful to generally solely hearken to the sport with none visible distractions. Audience atmosphere wants extra variation and a few parts are clearly out of steadiness, however I'd name this a superb begin. Audio already reacts to the sport occasions: gamers and destroyed ships are cheered, boring gameplay will get booed, mishaps trigger laughter and many others. https://soundcloud.com/ludovic_petunia/atp-audioclip-2872022 Most of the ambiences and results are taken (and often additional modified) from two asset packs: Ultimate Sound FX Bundle and Universal Sound FX. As selection is the important thing for a vivid audio background and most sounds should have a number of variations to randomly select from, these two match to my wants. Some sounds I recorded myself. Announcements are impressed by the practice station scene of "Les Vacances de Monsieur Hulot", and, in fact, you possibly can't have a correct area recreation with out organ music. I haven't actually been taking part in for ages, so it was enjoyable to improvise. Beside this audio factor, I've made a lot of miscellaneous fixes, enhancements and balancing in addition to taken a while to experiment with Unity's baked lighting and multi-scene workflow. Both are fairly unknown stuff to me, however they need to be one of the best ways to make enviornment stands fancier. So tons extra about that later. Logged Avaruustaistelupeli (ATP) – an area fight recreation– Free obtain from itch.io or IndieDB– Dev diary right here mobilelast Allright, time for half two of my lighting adventures. As my so-called workflow consists primarily of trials and errors, explaining it's fairly onerous. But I'll attempt to give a shallow rationalization. As I implied in a earlier publish, I discovered stadiums to be a superb candidate for baked lighting since they're just about the one static components within the recreation. Stadiums are available in three sizes, and every one among them should have two variations: one with lights on (used throughout ship choice and outcomes screens) and one solely lit by the solar (used in the course of the battle). Below are some photographs of the present fashions, lights on and off. Before the precise lighting, I used to be pressured to do some critical refactoring. My lights and light-weight settings had been in every single place, and a few directional lights had been already on baked mode; I don't know how they had been even working. So for starters, I corrected the sunshine sorts, removed some out of date gentle sources and renamed all objects appropriately so as to make the most of Unity's gentle explorer. The stadium fashions took some refining additionally. I attempt to keep on with the WW1-style, and 1910s stadiums had been tough locations. But nonetheless, to satisfy even probably the most rudimentary security requirements, I used to be pressured so as to add handrails in addition to inexperienced lights to point out the exit. And in fact I had so as to add the lights themselves to the ceiling and contained in the bins. As far as I do know (and proper me if I'm unsuitable), Unity can solely bake one set of sunshine maps per scene. This pressured me to desert the sooner stadium prefabs and begin utilizing a multi-scene workflow. It's a superb time for working towards: if there have been others working with the challenge, the multi-scene method could be virtually obligatory. I created six new scenes: gentle and darkish variations for every three arenas. These can now be loaded additively when the background enviornment is required in different scenes. Adjusting shadow map resolutions was fairly time consuming at begin, however I managed to determine an easy workflow. I begin by ramping up the lightmap decision in lighting settings till probably the most seen and necessary geometry is correct sufficient. Then I cut back the "scale in lightmap" -values (discovered within the MeshRenderer part) of the opposite fashions as little as attainable throughout the required accuracy. With filtering on, the resolutions could be stored surprisingly low, which reduces the baking time. Below is the picture of the sunshine maps I'm presently utilizing. Another tough activity was to arrange the sunshine probes for the dynamic objects (there will likely be spectators sooner or later, in any case). Unity's personal instruments are fairly dangerous particularly for putting the probes in round kinds. I ended up making a helper editor script and putting probes procedurally. End consequence works surprisingly nicely. Image beneath exhibits the probe positions. And right here's how they lit the placeholder spectators in gentle and darkish arenas. I'm already fairly happy with the small enviornment, which was the primary one I did; I nonetheless have to do the identical issues for medium and huge stadiums. Luckily, most components of the bigger stadiums are simply scaled (or pulled/pushed in Blender) variations of the small one, so that they share the identical textures and UV-mappings. This signifies that all arenas use the identical supplies, and there shouldn't be a lot work left after the small stadium is perfected. The actual problem is to animate the group. Regular skinned animation is approach too sluggish for 1000's of meshes, so all types of GPU trickery will likely be wanted. More about it later. Logged Avaruustaistelupeli (ATP) – an area fight recreation– Free obtain from itch.io or IndieDB– Dev diary right here mobilelast The stadium is sort of prepared for the viewers, however sadly massive crowds have a unfavorable impact on efficiency. This is especially on account of two causes: having a skeleton hierarchy for every spectator leads to an enormous variety of dynamic recreation objects, and Unity's batching doesn't help skinned meshes. These trigger an enormous CPU load to cope with. Solution is to animate meshes on GPU (in shaders), and use the batchable MeshRenderer as a substitute of its skinned variation. Unity doesn't have a built-in device for this, so I made one myself. I wrote a tough editor script that reads vertex positions of skinned mesh on every body and shops them right into a texture. A customized shader then repositions vertices in run-time by studying the positions from that texture. As I used a shader graph and my baker utility class could be very specialised for my wants, it's onerous to share any helpful code simply but. But for those who're , I discovered this article and this repository helpful. As a place to begin, operate AnimationClip.PatternAnimation units the mesh into a correct pose at a given time, and SkinnedMeshRenderer.BakeMesh can be utilized to extract the mesh knowledge at that second. In the shader, the vertex index is saved within the built-in variable vertexID. An attention-grabbing discovering is that for those who retailer every keyframe on a separate texture row, bilinear filtering will robotically deal with the animation mixing (see the article linked above). Resizing the feel to power-of-two (not essentially required in desktop growth) was a surprisingly complicated job that required an exterior render texture (or I've simply missed some too apparent utility operate). Here's what I'm doing for texture scaling (observe the feel format that's wanted for storing unfavorable values with first rate precision): public static void ResizeTexture(Texture2D pTexture, int pWidth, int pHeight) { var rt = RenderTexture.GetTemporary(pWidth, pHeight, 0, RenderTextureFormat.ARGBHalf, RenderTextureReadWrite.Default); RenderTexture.energetic = rt; Graphics.Blit(pTexture, rt); pTexture.Reinitialize(pWidth, pHeight, TextureFormat.RGBAHalf, false); pTexture.filterMode = FilterMode.Bilinear; pTexture.ReadPixels(new Rect(0f, 0f, pWidth, pHeight), 0, 0); pTexture.Apply(); RenderTexture.ReleaseTemporary(rt);} In the tip, animation baking wasn't almost as complicated as I feared, however resulted in some hilarious glitches. During the primary makes an attempt, fashions distorted closely and made the viewers seem like a horde of lovecraftian monsters; sadly I did not file a video of it. Of course there's nonetheless tons to do. Instead of repeating an identical gestures, every spectator wants particular person variation, so mixing of various animations at totally different speeds per particular person is required; this may in all probability introduce some batching points. I additionally have to bake normals and tangents and resolve smaller points with digital camera frustum culling (in all probability associated to AABB calculation). But at the very least I now have a strong base to construct on, already capable of run 1000's of animated spectators with out a noticeable FPS drop. I might make a prolonged weblog publish in regards to the topic. Perhaps I'll sooner or later. Writing in regards to the course of appears to be slower than the precise implementation, so hopefully somebody finds these useful. Besides the GPU magic I've additionally improved the background of the shipyard, experimented with GUI design and ACES tone mapping (I've to spice up up all these baked lights…) and many others. I'll come again to these within the upcoming posts. Logged Avaruustaistelupeli (ATP) – an area fight recreation– Free obtain from itch.io or IndieDB– Dev diary right here mobilelast I had a little bit flu, so final week wasn't superb for something that requires pondering. So, I did a couple of boring jobs that simply needed to be completed: created bigger enviornment fashions by scaling the smallest one, and utterly re-organized the binaries, prefabs and supplies in my challenge hierarchy; hopefully it will likely be simpler to truly discover one thing sooner or later. It was additionally a superb time to refactor cameras and idiot round with post-processing. I've all the time thought that the looks of the sport wants deeper contrasts, and the emissive lights must be introduced up extra with out interfering with the previous, industrial look. I made a decision to change the impartial tone mapping to ACES, because it ought to give higher distinction and extra room for changes. It tends to make the general picture darker, so I brightened up the lights and re-baked static shadows. I additionally added a secondary directional gentle to the battle scene so as to convey out the meteors and different areas shadowed by the solar (correct ambient lighting may do the identical trick, however I wasn't capable of make it look nearly as good). ACES boosts saturation, so I introduced it down a little bit in a shade grading. It is difficult to see objectively if the adjustments are for the higher or worse; I've to arrange a recreation testing workshop to see if the brightness is OK and colours could be clearly seen. The solely downside I got here throughout was that Unity's publish processing all the time units alpha values to 1. This prevents transparency, which in flip causes issues when rendering ships to GUI widgets by utilizing render textures. A customized shader might be wanted. This will naturally lead me into the subsequent activity: bettering UI graphics. Admittedly, I solely have a imprecise concept of what I'm after, however let's see the place it goes. Logged Avaruustaistelupeli (ATP) – an area fight recreation– Free obtain from itch.io or IndieDB– Dev diary right here mobilelast The recreation (and particularly the screenshots) appear too darkish. So though it's onerous to get the brightness proper objectively, I modified the ambient shade to gentle grey and elevated gentle intensities. I intentionally set the scene to be overly lit, as it's simpler to scale back the brightness in publish processing than enhance it. As lighting impacts how the totally different materials layers work, I needed to regulate them a little bit. I spent a superb whereas re-organizing supplies so as to simply export textures from Substance and take a look at them in Unity. And after a couple of curse phrases, I managed to bake brighter variations of all arenas. I additionally improved and changed most of the particle results. New explosions and smoke are already trying fairly neat. As I've by no means preferred Unity's particle system editor, I'll in all probability be utilizing solely VFX graphs sooner or later. Unfortunately my formidable GUI experiments weren't as profitable. I've to take one other method and see the place it goes. But subsequent I must repair some issues with the sport controller dealing with so as to prepare testing workshops. More about these within the subsequent publish. Test periods often reveal a ton of gameplay-related bugs, so I can then put graphics apart for some time. Logged Avaruustaistelupeli (ATP) – an area fight recreation– Free obtain from itch.io or IndieDB– Dev diary right here mobilelast Controller points are way more complicated than I anticipated, I appear to search out two new issues for each fastened one. Frustratingly, it appears that evidently every time I replace Unity's enter system to a more recent model, one thing will get damaged. Here's a fast abstract of issues I've handled in the course of the previous two weeks. Composite keyboard controls (WASD) stopped working once I up to date Unity and its enter system after the earlier launch (to Unity 2021.3.4f1 and enter system 1.3.0, if I interpret the model historical past accurately). In case somebody experiences the identical, I needed to set the management to "pass through" so as to make it work. Similarly, the controller's shoulder (or bumper, whichever you favor) buttons didn't work anymore in battles. In GUI they do work. Pass by -trick didn't work right here, so lastly I simply downgraded the enter system to 1.1.0, which fastened the difficulty. Gamepad scrolling within the shipyard didn't work after the newest ATP launch both. Even downgrading the enter system doesn't repair this, which has left me clueless. It appears that my digital mouse implementation (the code I posted nearly a 12 months in the past) causes conflicts between the precise system mouse and occasions I ship. This aborts dragging prematurely. I truly bought the dragging work by making a digital mouse system as a substitute of calling system mouse straight, however now I'm unable to make use of gamepad and mouse concurrently, which makes this resolution ineffective for me (Unity's reference implementation has the identical limitation). Enabling/disabling the digital mouse relying on the final used system may work. I'll strive that sooner or later. As this wasn't sufficient, there have been issues with the {hardware} as nicely. Crosshair jumped surprisingly when managed by the gamepad's joystick, and I spent a number of hours adjusting useless zones, filtering noise and many others. with out impact. After some time, I began getting suspicious and tried one other controller. Everything labored advantageous. https://gamepad-tester.com/ proves that the difficulty actually is within the controller: I don't really feel like combating with controls proper now, so I'll in all probability simply implement the frequent controller navigation to the menus (which was on my TODO checklist anyway), and use digital mouse solely within the shipyard (if I get it to work). Mouse is virtually obligatory within the shipyard, so I gained't be prioritizing this very excessive. But it's not all work with out enjoyable. Our first spectator invited his brothers to cheer me up (or mock me, resolve your self). More in regards to the crowd sooner or later posts. Logged Avaruustaistelupeli (ATP) – an area fight recreation– Free obtain from itch.io or IndieDB– Dev diary right here mobilelast More and extra spectators are coming in. And though there's nonetheless room for optimizations, I haven't seen a exceptional efficiency drop even with full stands. It is difficult to explain the technical course of with out being boring, however I'll strive. I might also share the baking utility and shader sooner or later, if I discover time to scrub it up and change the ugly hard-coded components. I began by modeling an especially low-poly spectator in Blender, then creating a number of totally different go well with textures for it in Substance; colours precisely match the lads's style in the course of the 1910s. Women's clothes from that period is way tougher to mannequin, so sadly girls are solely allowed in trousers and pretend mustaches for now. Next I imported the mannequin into Mixamo, rigged it, and exported all types of animation clips that spectators may do. In Unity I wrote a utility script that bakes clips into one sequence, and writes vertex positions and normals into textures. Extra variance is achieved by altering clip order. These textures are then given to the particular shader that performs the mesh deforming in GPU. Spectators might not look significantly good-looking by themselves, however their power is in numbers. Animation sequences and clothes textures could be joined freely so as to get an exponential variety of combos. It could be tedious to do that by hand, so I wrote one other script that creates materials for every cloth-animation-combination with various tint and animation pace. Script additionally helps totally different fashions, permitting girls, kids, monsters or no matter I'd mannequin sooner or later. But that's not my important precedence proper now. Here's the present scenario: Besides this, I hosted take a look at periods over the last week. Those would be the topic of the subsequent publish. So one thing in regards to the gameplay itself, for a change. Logged Avaruustaistelupeli (ATP) – an area fight recreation– Free obtain from itch.io or IndieDB– Dev diary right here mobilelast A delayed abstract of our testing session on 28.10. There had been surprisingly few points, and AI-opponents had been way more stable-minded and fewer suicidal than earlier than. I collected a number of the cooperative battles in a video. Of course, there's all the time room for enchancment. Missile flame particles had distracting gaps, which could be consistently seen in movies. I managed to repair this by feeding the missile's world coordinates to each "Spawn Over Distance" and "Initialize Particle Strip" parts within the VFX graph. Not certain if it is a correct approach, although. Mine explosions brought about an enormous shock wave that threw ships across the enviornment and doubtless broke the collision detection (time 2:48 in video above). This was in all probability due to a typo: the explosion power was ten instances too sturdy. But some sort of gravitation weapon could be a pleasant function… Stalemate buoy look brought about a complicated leap in digital camera focusing. Now the viewport must be tweened correctly. We additionally fought a grand, eight-ship match with two people and two AI pilots. Here's an uncut video of the match to show the sport stream and totally different ship designs. You can skip the ship choice components from bookmarks. https://www.youtube.com/watch?v=Okay-MeGf84ruI Logged Avaruustaistelupeli (ATP) – an area fight recreation– Free obtain from itch.io or IndieDB– Dev diary right here mobilelast Some of the pc opponent's stupidities have been bothering me for a very long time. Although AI performs reasonably nicely in micro-level (goals fairly precisely and even has some creativity with particular modules), it utterly lacks strategic pondering by taking silly dangers and losing ammunition in innocent conditions. The actual problem is, that AI must be much less aggressive and suicidal, however not too cautious. Otherwise battles have a tendency to finish up in a scenario the place AI refuses to do something. I made some enhancements to make issues higher: AI is now higher at calculating its close-combat power relative to opponents, and benefiting from it. It is aware of to maintain the space to stronger ships and rush in direction of weaker ones. Bonus objects aren't prioritized as excessive as earlier than. AI is much less keen to succeed in them when the win is already readily available. AI has had an inclination to shoot bonus objects with cannons for no cause. I believed I had fastened this a number of instances, however it all the time stored coming again. The remaining (hopefully) repair required a much bigger refactoring to the AI structure. My AI code is split into three components that may be executed concurrently: motion, cannons and particular features. The division is obvious and works nicely, however higher cooperation between the parts is required. For occasion, the bonus object concern was as a result of the AI first aimed cannons, however then tried to draw the bonus with a tractor beam. The latter habits re-positioned the crosshair, which made cannons shoot within the unsuitable place. Luckily, capturing solely takes one body, so it was sufficient to inform secondary modules to carry on till the cannons are completed. Once once more, I take into account this fastened. Expect to listen to extra about comparable points sooner or later. I discovered it onerous to visualise this topic, so right here's an unrelated image of a drunken spectator about to fall down the steps: Logged Avaruustaistelupeli (ATP) – an area fight recreation– Free obtain from itch.io or IndieDB– Dev diary right here Share FacebookTwitterPinterestWhatsApp Previous articleRegister For The Collegiate Chess League Spring 2023 Season Team FunTrove RELATED ARTICLES Indie Game Trinity Fusion – Beta Sign Up November 23, 2022 Indie Game Citizen Sleeper Revew – An Indie Game Sleeper Hit November 23, 2022 Indie Game Indie Retro News: Projects within the attic November 23, 2022 LEAVE A REPLY Cancel reply Comment: Please enter your comment! Name:* Please enter your name here Email:* You have entered an incorrect email address! Please enter your email address here Website: Save my name, email, and website in this browser for the next time I comment. Most Popular Register For The Collegiate Chess League Spring 2023 Season November 23, 2022 Gobble-Gobble ROAR! 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In the Windows Update History page, you will now see a list of updates and when they were installed….How to see the update history with the Settings app
- Open Start menu.
- Go to Settings.
- Navigate to Update & Security > Windows Update.
- Click on 'View update history'.
How do I know if a Windows security Update is installed?
In the search box, type Update, and then, in the list of results, click Windows Update. In the left pane, click View update history. It will show all installed updates.
How do I check if I have the latest security Update?
Get security updates & Google Play system updates
- Open your device's Settings app.
- Tap Security.
- Check for an update: To check if a security update is available, tap Google Security checkup. To check if a Google Play system update is available, tap Google Play system update.
- Follow any steps on the screen.
How do I check my security patches Windows 10?
To do so, open Control Panel and navigate to Programs > Programs and Features, then click "View installed updates." You'll see a list of every update Windows has installed.
What are the steps to check for security updates on your computer?
Checking for Windows Updates on Your PC
- Close all applications you have running.
- Click on the Start menu and select the Settings icon.
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How do I find a list of installed Windows updates?
See your update history with Command Prompt and SystemInfo
- Open Search/Cortana.
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How do I get a list of installed Windows patches?
To view the history list of Windows 10 updates using Command Prompt:
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- Type the following command to view the update history and press Enter: wmic qfe list.
- Check the Windows Update history of your device.
How do I Check Android security updates?
To check if a security update is available, tap "Google Security Checkup". To check if a Google Play system update is available, tap "Google Play System Update".
What is the latest security update for Windows 10?
Windows 10 October 2020 Update (version 20H2) Version 20H2, called the Windows 10 October 2020 Update, is the most recent update to Windows 10.
How do I know if my computer needs updates?
Open Windows Update by clicking the Start button , clicking All Programs, and then clicking Windows Update. In the left pane, click Check for updates, and then wait while Windows looks for the latest updates for your computer.
What does security update mean?
Security Risks of Using an Outdated Phone
In simple terms, security updates are software updates primarily focused on patching existing bugs or flaws to improve software security. So if a hacker discovers a way to take over your device remotely, this is a bug and a security update can help fix it.
Does Windows 10 automatically install updates?
By default, Windows 10 updates your operating system automatically. However, it is safest to manually check that you are up to date and it is turned on. Select the Windows icon in the bottom left of your screen. Click on the Settings Cog icon.
What is Android security update?
Published July 6, 2022 | Updated July 7, 2022. The Android Security Bulletin contains details of security vulnerabilities affecting Android devices. Security patch levels of 2022-07-05 or later address all of these issues. To learn how to check a device's security patch level, see Check and update your Android version.
What is my Android security patch level?
Scroll down to the bottom and tap on System. Tap on About [device],About phone or System update. It will be located at the bottom of the list.
Is Windows 10 still receiving security updates?
Windows 10, version 1507, 1511, 1607, 1703, 1709, and 1803 are currently at end of service. This means that devices running these operating systems no longer receive the monthly security and quality updates that contain protection from the latest security threats.
Should I update to Windows 10 21H1?
Windows 10, version 21H1 is designated for broad deployment. As always, we recommend that you update your devices to the latest version of Windows 10 as soon as possible to ensure that you can take advantage of the latest features and advanced protections from the latest security threats.
What happens if you don't update your computer software?
However, if you don't install any updates, your system will be prone to ransomware and malware infections. Besides the major operating system updates, Microsoft releases minor updates frequently. The Windows operating system checks for updates once per day, and typically, it won't find new ones.
Are Android updates necessary?
The updates are sometimes important, and they're nice to have, but they aren't essential. As you have read above, your phone will likely work fine on the older version of Android, and the developers will maintain support for it. And remember, a lot of phones might get updated, but it can take a while.
Why is it important to keep your security software update?
Updates can prevent security issues and improve compatibility and program features. Software updates are necessary to keep computers, mobile devices and tablets running smoothly — and they may lower security vulnerabilities. Data breaches, hacks, cyber attacks and identity theft have all been in the news.
Why are the security updates needed?
As you might expect from the name, these updates are also very important for security reasons. Some bugs present security risks, and these can be quickly addressed with an update. Security updates can also fix vulnerabilities to new attacks that have cropped up.
How often is Microsoft Defender update?
Hi Robby, Windows Defender AV issues new definitions every 2 hours, however, you can find more information on definition update control here, here and here. Also note that by turning on 'cloud protection' on the protected machines you can reduce definition update time to real-time.
Is Windows Defender automatically on?
Important security info
If you have another antivirus app installed and turned on, Microsoft Defender Antivirus will turn off automatically. If you uninstall the other app, Microsoft Defender Antivirus will turn back on automatically.
Why is my computer not automatically updating?
How do I turn on automatic updates in Window 10? First, you go to Settings. Click on Update & Security and then select Windows Update. Click on the Advanced Options and then make sure Automatic is selected under Choose how updates are installed.
What versions of Android are no longer supported?
With the release of Android 10, Google has stopped support for Android 7 or earlier. This means that no more security patches or OS updates will be pushed out by Google and Handset vendors as well.
What is the oldest Android version still supported?
The current operating system version of Android, Android 10, as well as both Android 9 ('Android Pie') and Android 8 ('Android Oreo') are all reported still to be receiving Android's security updates. However, Which? warns, using any version that is older than Android 8 will bring with it increased security risks.
How can I improve my Android security?
How to secure your Android phone with built-in tools
- Prevent downloads from unknown sources.
- Keep Android OS up to date.
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- Enable purchases with biometric authentication.
- Run a Play Protect scan.
- Enable Play Protect.
How can I update my Android device?
How do I update my Android ™?
- Make sure your device is connected to Wi-Fi.
- Open Settings.
- Select About Phone.
- Tap Check for Updates. If an update is available, an Update button will appear. Tap it.
- Install. Depending on the OS, you'll see Install Now, Reboot and install, or Install System Software. Tap it.
What is the latest version of Android?
The latest version of Android OS is 12, released in October 2021. Learn more about OS 12, including its key features. Older versions of Android include: Red Velvet Cake (OS 11)
Is there a new Windows Update 2022?
The August 2022 security update release, referred to as our "B" release, is now available for Windows 11 and all supported versions of Windows 10. We recommend that you install these updates promptly.
What is the newest version of Windows 2022?
On May 9, 2022, Microsoft released Windows 11 on physical media in the form of a boxed USB drive and product key.
What will happen to Windows 10 after 2025?
After October 2025, Microsoft will stop releasing security updates for Windows 10. Although Windows 10 devices will continue to function, security vulnerabilities affecting the operating system will not be remedied, leaving affected computers susceptible to compromise.
How long will Windows 10 version 21H1 be supported?
As an H1-targeted release, 21H1 is serviced for 18 months from the release date for devices running Windows 10 Enterprise or Windows 10 Education editions. For details on how to update your device, or the devices in your organization, see How to get the Windows 10 May 2021 Update.
Do I need to update to Windows 21H2?
In the case that you have version 20H2, you should upgrade to version 21H2 as soon as possible since the older release will reach the end of support on May 10, 2022, and after that day, Microsoft will stop releasing updates.
How long do Android phones last?
Android phones will last anywhere between 2 to 4 years before performance may degrade. As long as the phone can connect to the internet, the OS can be upgraded. The main factors to consider about replacing Android handsets are battery performance, operational issues, and memory.
Is it bad to update computer?
In addition to bug fixes and new features, OS updates include vital security patches for newly found system vulnerabilities. These are vulnerabilities that hackers know about and are busy exploiting with malware and other malicious threats.
How do I update software on my computer?
How do I run Windows Updates?
- Go to the start button.
- Search for the application called Software Center.
- Click on the Updates tab.
- Install the updates using the Install All button or click on each one individually and install them separately.
How often should you update your phone?
It's an upsetting reality that some manufacturers (and customers) hope to change. But until that change comes, Android users should seriously consider replacing their phone every two years.
What happens if you never update your phone?
Here's why: When a new operating system comes out, mobile apps have to instantly adapt to new technical standards. If you don't upgrade, eventually, your phone won't be able to accommodate the new versions–which means you'll be the dummy who can't access the cool new emojis everyone else is using.
What does it mean when it says your software is up to date?
Device manufacturers and app developers will usually release software updates regularly until they decide their product is unsupported. These updates will often contain new features, fixes for bugs and performance improvements.
Are software updates free?
Software Update
Alternatively, software updates, sometimes called a software patch, are something you download for free. It's an elevated version of the application, operating system or software that you currently have.


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- 작성자 Ricardo
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Case 3:21-cv-02065-M Document 12 Filed 10/08/21 Page 3 of 31 PageID 80
BNSF Ry. Co. v. Int'l As'n of Sheet Metal Air, Rail & Transp, Workers-Transp, Div.,
973 F.3d 326 (5th Cir. 2020) ............................................................................................. 15
Case 3:21-cv-02065-M Document 12 Filed 10/08/21 Page 4 of 31 PageID 81
Norris-LaGuardia Act,
Case 3:21-cv-02065-M Document 12 Filed 10/08/21 Page 5 of 31 PageID 82
moved this Court pursuant to Fed. R. Civ. P. 65 for a temporary restraining order and for further
preliminary and injunctive relief against Defendant Southwest Airlines Co. ("Southwest Airlines"
or "Defendant"). The injunctive relief sought in this action is necessary to stop Defendant from
unilaterally issuing new policies and procedures which impact the Pilots' pay, rules, and working
conditions without first exerting "every reasonable effort" to not violate the parties' status quo
under the Railway Labor Act, 45 U.S.C. § 151 et seq. ("RLA" or the "Act").
Emergency Extended Time Off ("ExTO") Program, a COVID quarantine policy, a Vaccine
Participation Pay Program ("VPPP"), a Flight Crew Training Instructors Program, and a
mandatory COVID vaccine policy. Each new policy was unilaterally rolled out by Southwest
Airlines without negotiations or bargaining by the Company with SWAPA. Each new policy
violates the parties' status quo and is an issue within a major dispute that requires Southwest
Airlines to maintain the parties' status quo while negotiating with SWAPA. Instead, Southwest
Airlines is acting as if it has a force majeure provision within the parties' collective bargaining
agreement ("CBA") when it does not. Because Southwest Airlines keeps taking unilateral actions
in violation of the RLA, this motion and the requested injunctions are necessary.
Pursuant to Fed. R. Civ. P. 65, SWAPA hereby moves the Court for a temporary restraining
order and for further preliminary injunctive relief against Southwest Airlines. The injunctive relief
sought will restrain the Carrier from interfering with the federal, Railway Labor Act-protected
rights of its pilots represented by the SWAPA. Counsel for SWAPA has conferred with counsel
for Southwest Airlines in a good-faith attempt to resolve this matter by agreement; however, no
agreement could be made, as Southwest Airlines denies its actions are in violation of the Railway
1. The parties' CBA covered the period from September 1, 2012 through August 31,
2020. Sixty days prior to the expiration of the term of the CBA, the Union served notice to
Southwest for an early reopener on November 1, 2019, pursuant to CBA Section 28, which
provides that "[e]ither party may give written notice of its desire to modify the Agreement at least
sixty (60) days prior to March 1 of each year beginning March 1, 2020." (Murray Declaration,
begin direct negotiations under Section 6 of the RLA. (Murray Declaration, Paragraph 4, APP 3).
3. Even early in the negotiation process, Southwest Airlines did not engage in
bargaining with SWAPA and, instead, took unilateral action. Several times, SWAPA had to send
written demands to Southwest Airlines for the carrier to cease its unilateral actions to change the
4. On January 10, 2020, Captain Murray's predecessor, the prior SWAPA President,
Captain Jon Weaks, had to send Southwest Airlines a cease-and-desist demand letter when
Southwest Airlines attempted to change and negotiate new working rules and pay changes directly
with check airmen under the guise of a "Check Airmen scheduling test." (Murray Declaration,
5. On January 27, 2020, SWAPA had to object to Southwest Airlines' unilateral change
to a delayed implementation of the Pilots' deferral rate change to their 401(k) accounts -- without
bargaining with SWAPA -- and demanded that Defendant Southwest Airlines honor the status
pharmacy benefits manager, which resulted in the reduction of drug benefits for the Pilots, again
without bargaining with SWAPA. (Murray Declaration, Paragraph 8, Exhibit 4, APP 4 and APP
7. Then, during the rise of the COVID-19 pandemic, Southwest Airlines' Management
began to threaten furloughs and sought sizable concessions from SWAPA, along with the other
8. The parties' CBA does not contain a force majeure clause. Without a force majeure
clause, Management could not be relieved of its obligation to perform its contractual obligations
9. When COVID hit full force in March 2020, Southwest Airlines' pattern of taking
without bargaining continued. In the pandemic, the world became shuttered and air travel
10. Under the parties' CBA, Southwest Airlines is obligated to meet pay guarantees for
its Pilot group. (See CBA provisions within Section 4 and Section 4 H. APP 80-101, APP 84) To
reduce costs, Southwest Airlines acted as though it had force majeure rights by declaring an
emergency and implementing an Emergency Time Off ("ETO") program, and later an Emergency
Extended Time Off ("ExTO") program, that offered Pilots the option to not fly and not be paid, in
contravention of the terms and conditions of the CBA. (Murray Declaration, Paragraph 12, APP
11. SWAPA objected to Management's direct negotiations with the Pilot group on these
changes to Pilots' working conditions, rules, and pay. By a letter dated March 26, 2020, SWAPA
objected to these programs as another status quo violation and demanded bargaining. In response
to SWAPA's demand, Management did come to the bargaining table and negotiated with SWAPA
on the ETO program. The parties' agreement was memorialized in the ETO MOU (Memorandum
of Understanding), fully executed on May 27, 2020. (Murray Declaration, Paragraph 13, Exhibit
12. For the subsequently imposed ExTO program, SWAPA also tried to reach an MOU
with Southwest Airlines but was unsuccessful because Management took the position that
bargaining was not necessary. Management's anti-union sentiment against SWAPA was high (and
continues to be high). Ultimately, no agreement on the ExTO program was ever reached. Pilots
have not only taken time off on ExTO under this extra-contractual program, but many have already
left and been recalled. Southwest Airlines saw no issue with using the pandemic (despite the
absence of a force majeure clause) to bargain directly with Pilots for working conditions, rules,
and pay that was beyond the scope of the CBA (and despite the RLA's bargaining and non-
13. Around the same time, on March 11, 2020, Southwest Airlines further availed itself
of force majeure rights by issuing an emergency pandemic policy that it is using to improperly and
illegally trump the CBA. As part of its "proactive steps to protect Employees in the workplace in
the event of an infectious disease outbreak," Southwest Airlines included information that one
would expect in such a company pandemic policy. It adopted the Center for Disease Control
("CDC") guidelines on how to prevent the spread of infection in the workplace, such as frequent
hand washing and avoiding close contact with people who are sick. (Murray Declaration,
14. The policy also provided for situations where employees are to be quarantined for
both contracting an infectious disease and having been exposed to an infectious disease. Therein,
Southwest Airlines expressly reassured all employees that they "will be paid" for any missed work
if they got sick from an infectious disease or if they were directed to quarantine by Management
or the CDC. It is this pay reassurance portion of the policy that Management unilaterally changed
later to take away Pilot pay, a right that Management does not have vested in the CBA. (Murray
15. At the time, the pay reassurance was critical to preventing Southwest Airlines'
operations from grinding to a complete stop, as tens of thousands of people were dying from the
COVID-19 virus and hospitals had to turn away patients because they ran out of hospital beds.
Schools, government buildings, and courts closed their facilities to the public and restaurants and
numerous other businesses largely shut down. It was under these conditions that Southwest
Airlines needed its front-line employees to continue to report for duty and for its Pilots to keep
flying the airline's fleet of 737s to keep the airline operational. (Murray Declaration, Paragraph
16. The Pilot work group is among the most at-risk work groups immediately after first
headquarters' offices to work from home and met virtually, but Pilots, along with other front-line
workers, did not have that option. Pilots, especially, were at a heightened risk due to the nature of
17. During flight operations, Pilots are confined to the cockpit for long hours, which
makes it impossible for Pilots to maintain safe social distancing under both the CDC Guidelines
and Southwest Airlines' Infectious Disease Control Policy. (Murray Declaration, Paragraph 19,
18. Additionally, while management employees sheltered at home, Pilots were on the
road every day, in airport terminals, at hotels with drastically reduced services, and crammed into
hotel shuttles to and from their day of work. (Murray Declaration, Paragraph 20, APP 6).
19. While management employees with minor children (now no longer in schools) were
able to work with their kids at home, Pilots could not, and their families and children were equally
put at risk of infection each time the Pilots returned home from a trip. (Murray Declaration,
20. During this time, state and local governments around the country were issuing
progressively stricter rules against being in public. However, because of their role in global
transportation, Pilots were deemed an "essential critical infrastructure workforce." As they flew
their trips, Pilots had to carry on their persons a copy of an official letter from CEO Gary Kelly –
about March 23, 2020 – to prove that they were exempt from state and local laws that prohibited
individuals from being in public and to avoid arrest if stopped by local law enforcement authorities.
21. Indeed, conditions were so dangerous for Southwest Pilots that SWAPA had to
make a demand on Defendant Southwest Airlines to protect crew health and safety. In SWAPA's
April 20, 2020 letter, SWAPA demanded, among other things, for Southwest Airlines to sanitize
the aircraft cockpit daily, to provide Pilots with PPE (which was extremely scarce), and to provide
Pilots with notification when they had been exposed to infected crew or passengers that was
consistent across all eleven of Southwest Airlines' domiciles. SWAPA had received membership
complaints that notification by chief pilots varied depending on which domicile the Pilot was based
in, and even within the same domicile, notification may have been different from chief pilot to
chief pilot or assistant chief pilots. (Murray Declaration, Paragraph 23, APP 7).
22. Since March 2020, the COVID pandemic has gone through several surges and peaks.
After the first spike in the summer of 2020, America braced itself for a second spike during the
fall of 2020. Vaccination relief did not come until first quarter of 2021, and even then, vaccine
supply was extremely limited, on an Emergency Use Approval only, and not available to the
general public. As vaccine supplies increased across the country, the airlines saw increased
23. The relief from vaccines, however, was short-lived when the Delta variant of the
coronavirus emerged, proving to be far superior in transmission than the original virus, being twice
24. Today, the number of people infected with the Delta variant is increasing, once again
crowding hospitals beyond capacity. Other mutations of the coronavirus are popping up around
the world. The first case of the Lambda variant in the U.S. has shown up at the Houston Methodist
Hospital. Studies show that Lambda may be resistant to vaccines. (Murray Declaration, Paragraph
25. Throughout the pandemic, SWAPA's dedicated Pilots have continued to come to
work and perform their duty. Many have had close contact with infected individuals while at work.
They have gotten infected. A few have died. Many more have not recovered well enough to fly.
26. As soon as the pandemic hit, Southwest Airlines began stockpiling cash from all
available sources, including the Payroll Support Program ("PSP") for the airline industry as part
of the federal CARES Act. Southwest Airlines went from having a cash balance of $4.1B in 2019
to over $24B during the pandemic. (Murray Declaration, Paragraph 28, APP 8).
27. Despite being cash positive, Southwest took advantage of the COVID pandemic. In
October 2020, Management demanded concessions from all its labor unions, including SWAPA.
Southwest Airlines again made an "enterprise decision" to seek a 10% pay cut from each labor
worker. With the Pilot group, Management sought a 10% pay cut and demanded to add a force
majeure clause into the CBA, which it did not have. (Murray Declaration, Paragraph 29, Exhibit
28. In response, SWAPA stood up against Management's demands, pointing out the
lack of justification for the concession demands and gave Management alternative concrete
solutions to create efficiencies and savings for the airline to weather the pandemic and compete.
Management was not receptive to SWAPA's solutions, and on December 3, 2020, sent WARN
Act notices to 1,221 Pilots, notifying them that they would be furloughed over the Christmas
29. As the pandemic dragged on, Southwest Airlines began experiencing staffing issues.
These staffing issues were a direct result of the extra-contractual ExTO program rolled out
unilaterally by Southwest Airlines. Once again, SWAPA had anticipated these staffing issues
months earlier and offered solutions to Management. As hundreds of flights are being canceled
and Pilots are being overworked on the line and stranded overnight, all the while still at risk of
COVID, and ever more with the Delta and Lambda strains, SWAPA has been vocal in demanding
SWAPA has continued to build throughout the pandemic. (Murray Declaration, Paragraph 31,
30. Southwest Airlines' attitude toward Pilots is cavalier, indicating that Management
thinks it can act unilaterally during this global emergency and hiding behind its "enterprise
decision" excuse to refuse to bargain with SWAPA. However, Southwest Airlines did in fact
bargain for and reach agreement with the flight attendants' union over these exact same issues.
31. During this same period, other airlines met with their respective labor unions and
bargained for new working conditions and rules that were impacted by the pandemic. American
Airlines, United Airlines, and Delta Airlines are amongst those airlines with letters of agreement
in place to cover the working conditions, rules, and pay related to COVID. Unlike the case for
Southwest Airlines, such codifications at the other airlines have greatly encouraged vaccinations
by the pilots of those airlines and the reduction of the chances of COVID-19 transmission in the
32. Having negotiated and codified COVID Letters of Agreements with its labor unions
back in May 2020, United Airlines reported at the end of September 2021 that 99.5% of its
employees have been vaccinated. (Murray Declaration, Paragraph 34, APP 10).
33. On the other hand, Southwest Airlines' response to the cost of operating the airline
in the pandemic was to shift that cost to its unionized labor. Despite its reassurances that
employees will be paid for the company's operational changes due to COVID, Southwest Airlines
34. Even though its Infectious Disease Control Policy was supposed to be an "enterprise
decision" applicable to all employees, Southwest Airlines imposed random and unilateral changes
to how the policy applied (or not) to Pilots, all without bargaining. Once again, Pilots were told
different things depending on domicile and chief pilots. SWAPA leadership reached out to its
counterparts at the airline to voice objections over Southwest Airlines' failure to bargain and taking
of rights. Each time, SWAPA was rebuffed. (Murray Declaration, Paragraph 36, APP 10).
35. By December 2020, Management began directing Pilots into mandatory quarantines
and only those Pilots who had crew close contact were paid for the work they missed. The company
forced hundreds of pilots into unpaid time off. By June 16, 2021, Management continued directing
Pilots into mandatory quarantines, but stopped paying them for missed work. This all was being
done verbally by Management chief pilots. (Murray Declaration, Paragraph 37, APP 10).
36. On May 11, 2021, Southwest Airlines revised its Infectious Disease Control Policy.
One glaring change was made. The critical reassurance that employees "will be paid" for COVID-
related events was removed. Instead, it now says "may" be paid - at Management's discretion.
(Murray Declaration, Paragraph 38, Exhibit 8, APP 10-11 and APP 30-33).
of their intent to mandate vaccinations, on August 11, 2021, SWAPA's president, Captain Murray,
wrote a demand letter to Southwest Airlines, reiterating the need for the parties to come to the
table and bargain over the mandates already (unilaterally) imposed by Southwest Airlines, and
those which may be imposed, that alter Pilots' working conditions, rules and pay. He expressly
stated that, "a dedicated meeting to address the above is critical," and "SWAPA stands ready to
seek relief from the federal court if management takes such unilateral action and refuses to
bargain." (Murray Declaration, Paragraph 39, Exhibit 9, APP 11 and APP 34-35).
38. Southwest Airlines' response of August 21, 2021 disagreed, stating that negotiations
were not required, as "current CBA contains broad language granting management the right to
unilaterally take action on those issues." (Murray Declaration, Paragraph 40 Exhibit 10, APP 11
39. After these failed attempts to convince Management to negotiate and reach
agreement with SWAPA over Pilots working conditions, rules and pay, SWAPA had no choice
but to seek court intervention in upholding the Railway Labor Act. SWAPA filed the instant
lawsuit on August 31, 2021. (Murray Declaration, Paragraph 41, APP 11, and Docket No. 1).
September 15, 2021, Southwest Airlines unilaterally implemented another policy that changes
Pilots' working conditions, rules, and pay, i.e., its "Vaccine Participation Pay Program" or
"VPPP." This new program offered Pilots additional pay to get vaccinated, and also threatened to
take away Pilots' pay if they are not vaccinated by a deadline. It was not bargained with the Union.
Management gave SWAPA a "heads up" the day before, on September 14, 2021, that Southwest
Airlines would implement the new policy but omitted any details. By unilaterally imposing it on
the Pilot work group, Southwest Airlines was, in essence, negotiating directly with the Union's
membership to change its working conditions, rules, and pay (despite Southwest's duties under
41. The unilateral vaccine incentive program was imposed after SWAPA filed the
federal status quo lawsuit. Since then, the parties met twice virtually to discuss COVID-related
issues. In those virtual calls, on September 2 and 7, 2021, SWAPA tried to engage Management
in negotiations to reach agreement. SWAPA presented Management with a draft MOU that covers
the COVID-related issues that have been festering since March 2020. Southwest Airlines did no
more than hold court to allow SWAPA to present its draft MOU. It provided no counteroffer, nor
did it signal its intent to implement yet another unilateral program, only days later. (Murray
42. As soon as SWAPA learned of Management's plan to roll out its unilateral Vaccine
Incentive Plan, Captain Murray wrote to Captain Bob Waltz, Southwest Airlines' Vice President
of Flight Operations to demand confirmation that the Vaccine Participation Pay Program did not
apply to Pilots. Captain Murray stated to Captain Waltz that, "[t]o roll out a program unilaterally
under these circumstances is clear evidence of bad faith bargaining by the Company and de facto
negotiating directly with SWAPA's membership, illegal under the RLA as the parties are in
Section 6 negotiations." (Murray Declaration, Paragraph 44, Exhibit 11, APP 12 and APP 37-38).
43. Captain Waltz responded in writing on September 17, 2021. In his letter, he
described Management's VPPP. (Murray Declaration, Paragraph 45, Exhibit 12, APP 13 and APP
44. The following Thursday, on September 23, 2021, SWAPA learned unofficially that
Management had plans to start training Pilots to be flight crew training instructors, a job function
traditionally performed by non-SWAPA employees and represented by a separate labor union, i.e.,
the TWU 557 – the Southwest Flight Crew Training Instructors Union. SWAPA immediately
sought clarification from Southwest Airlines, who admitted that Management had indeed solicited
SWAPA Pilots to take on this new job function that would change those Pilots' working
conditions, rules, and rates of pay. While SWAPA appreciated Southwest Airlines' need for more
instructors to clear up the training logjam it was experiencing from having Pilots return from ExTO
(the earlier unilateral program by Management that paid Pilots outside the CBA for an extended
leave of absence), SWAPA disagreed with Management once again negotiating directly with its
Pilot group to create a new category of job function without the Union's agreement. (Murray
45. Southwest Airlines had not engaged SWAPA on this training effort, even though it
had been in the works for months. Under SWAPA's insistence and working with a select few at
Southwest Airlines, SWAPA proposed an Instructor MOU that the parties agreed to on September
24, 2021, which now awaits ratification by SWAPA Board of Directors as part of the Union's
46. As the Instructor MOU hung in the balance, on Friday afternoon, October 1, 2021,
Southwest Airlines gave SWAPA a "heads up" that a vaccine mandate - again unilateral, again
without specifics – was imminent. On October 3, 2021, Captain Murray wrote a letter, this time
to Gary Kelly, the Chief Executive Officer at Southwest Airlines, to voice the Union's fierce
objections to Management's open disregard for its obligation under the RLA to bargain in good
faith. SWAPA demanded that Southwest cease and desist from rolling out the vaccine mandate
without bargaining and reaching agreement with SWAPA. SWAPA notified Mr. Kelly of the
Union's intent to seek injunctive relief against Southwest Airlines to compel Management to stop
taking unbargained-for rights. (Murray Declaration, Paragraph 48, Exhibit 13, APP 13-14 and APP
47. On October 4, 2021, Southwest Airlines announced its vaccine mandate, which
made vaccination a new condition of employment for Pilots and threatened termination for non-
compliance, all of which conflicts with the parties' CBA and has not been negotiated with nor
agreed to by SWAPA. Gary Kelly made the announcement at 2:00 p.m. That morning, Southwest
Airlines set up a call with SWAPA to "brief" SWAPA of the new vaccine mandate about to be
implemented. There was no give and take within the briefing. Instead, Management hurriedly
dumped its plans on the Union. By this eleventh hour, there was no time nor opportunity for any
meaningful dialogue or input, let alone bargaining. (Murray Declaration, Paragraph 49, APP 14).
48. That same afternoon, on October 4, 2021, Captain Alan Kasher, Executive Vice
President of Daily Operations, joined a SWAPA Board of Directors meeting. In that meeting,
Captain Kasher fielded many questions and concerns by the SWAPA Board members. It was
highlighted that Southwest Airlines' biggest competitors, i.e., United Airlines, Delta Airlines, and
American Airlines, all had collectively bargained-for rights. Specifically, each of the other airlines
had reached out to their respective labor unions at the onset of the pandemic and by May 2020 had
negotiated COVID-related letter of agreements prior to changing the working conditions, rules,
and pay of their unionized work force. (See Declaration of Mark Myers, Director of Pilot
Negotiations and Contract Administration for the Allied Pilots Association ("APA") regarding
approximately 14,000 pilots, APP 285-87) When asked point blank, Captain Kasher could only
admit that Southwest Airlines was wrong in failing to collectively bargain. (Murray Declaration,
49. Southwest Airlines' cavalier disregard for the RLA has a significant, consequential,
and detrimental impact on SWAPA and its membership. Southwest Airlines' continued and
repeated unilateral actions have wholly upended the status quo and effectively destroyed the
Union's ability to collectively bargain on behalf of its members in compliance with the RLA.
50. With each of these unilateral actions, our phones and emails at SWAPA are being
flooded with questions and concerns from membership. The resulting chaos of these and a
multitude of unanswered questions have resulted in a drain on SWAPA's resources and the
Union's ability to represent its membership. This bargaining structure, or lack thereof, cannot be
what was envisioned by the drafters of the RLA. (Murray Declaration, Paragraph 52, APP 15).
Under the law of this Circuit, preliminary injunctive relief is appropriate if (1) there is a
substantial likelihood that the moving party will prevail on the merits, (2) there is a substantial
threat of irreparable injury, (3) the balance of harms tips in the movant's favor, and (4) the public
interest supports an injunction. See, e.g., BNSF Ry. Co. v. Int'l Ass'n of Sheet Metal, Air, Rail &
Transp. Workers-Transp. Div., 973 F.3d 326, 333 fn. 5 (5th Cir. 2020); Pendergest-Holt v. Certain
Underwriters at Lloyd's of London, 600 F.3d 562, 568-69 (5th Cir. 2010); Plains Cotton Co-op.
Ass'n v. Goodpasture Comput. Serv., Inc., 807 F.2d 1256, 1259 (5th Cir. 1987); Enterprise Int'l,
Inc. v. Corporacion Estatal Petrolera Ecuatoriana, 762 F.2d 464, 471 (5th Cir. 1985).
However, in cases where a party has alleged violations of the RLA, the court need not make
a finding of irreparable harm or injury and may issue a preliminary injunction to put an end to the
non-moving party's actions. See, e.g., Bhd. of Ry. Trainmen v. Central of Georgia Ry., 305 F.2d
605, 609 (5th Cir.1962)(holding that if rail carrier's motivation is to destroy the representative
through the imposition of improper discipline, "the public interest, if nothing else, would make
injunctive relief appropriate if not compelled."); see also Consol. Rail Corp. v. Ry. Lab.
Executives' Ass'n, 491 U.S. 299, 303 (1989)(holding that violations of the statutory requirements
of the RLA may be enjoined without the customary showing of irreparable injury); Wheeling &
Lake Erie Ry. Co., 789 F.3d 681, 691 (6th Cir. 2015)(same); United Airlines v. Int'l. Ass'n of
Machinists, 243 F.3d 349, 362 (7th Cir. 2001)(affirming a preliminary injunction without a finding
of irreparable harm); Division No. 1, Bhd. of Locomotive Engineers v. Consolidated Rail Corp.,
Moreover, the Norris-LaGuardia Act, 29 U.S.C. § 101, et seq., does not deprive this Court
of jurisdiction to issue the requested injunctive relief. See Bhd. of R.R. Trainmen v. Howard, 343
U.S. 768, 774 (1952). Norris-LaGuardia states that before issuing a preliminary injunction in any
case involving a labor dispute, the district court must hear testimony of witnesses in open court
(a) that unlawful acts have been threatened and will be committed unless restrained
or have been committed and will be continued unless restrained. . . .;
(b) That substantial and irreparable injury to complainant's property will follow;
(c) That as to each item of relief granted greater injury will be inflicted upon
complainant by the denial of relief than will be inflicted upon defendants by the
granting of relief;
(e) That the public officers charged with the duty to protect complainant's property
are unable to unwilling to furnish adequate protection.
29 U.S.C. § 107. But the requirements of Norris-LaGuardia do not substantially change the court's
preliminary injunction analysis; to grant the moving party's motion, "the Court must find that
Plaintiffs have shown a substantial likelihood that they can prevail on their RLA claims and must
also find that without a preliminary injunction Plaintiffs will suffer irreparable harm which
outweighs any harm caused," to the defendant. Skywest Pilots ALPA Organizing Committee v.
The instant labor dispute is governed by the provisions of the RLA, which defines two
types of disputes that may arise between covered employers and the labor organizations
representing their employees. 45 U.S.C. § 151 (a)(4) and (a)(5). Disputes falling under Section
151 (a)(4) ("concerning rates of pay, rules, or working conditions") have been coined by the United
States Supreme Court as "major" disputes. Elgin, Joliet and Eastern Railway Company v. Burley,
325 U.S. 711, 723, 65 S. Ct. 1282, 1289-90 (1945). A "major" dispute concerns contract formation
or the amendment of a collective bargaining agreement, and the resolution of such disputes is
governed by § 6 of the RLA, 45 U.S.C. §§ 156, 181; Western Airlines, Inc. v. International
Brotherhood of Teamsters, 480 U.S. 1301, 1302 (1987). The RLA establishes "major" dispute
resolution procedures, including, but not limited to, negotiation between the parties, mediation
before the NMB, and voluntary interest arbitration. Consolidated Rail Corporation v. Railway
Labor Executives' Association, 491 U.S. 299, 109 S. Ct. 2477 (1989). Where an employer asserts
a contractual right to take contested action, the ensuing dispute is "minor," under Railway Labor
Act, if the action is arguably justified by terms of parties' collective bargaining agreement. In
contrast, if the employer's claims are frivolous or obviously insubstantial, the dispute is "major."
Id. at 306. The Supreme Court has ruled: "In a situation in which a party asserting a contractual
basis for its claim is 'insincere' in so doing, or its 'position [is] founded upon insubstantial
grounds,' the result of honoring that party's characterization would be to undercut 'the prohibitions
of § 2, Seventh, and § 6 of the Act' against unilateral imposition of new contractual terms." Id.
While parties are engaging in the RLA's "major" dispute resolution procedures, they "are
obligated to maintain the status quo, and the employer may not implement the contested change
in rates of pay, rules, or working conditions." Id. at 302-03. As such, it is generally recognized
that a "major" dispute arises where the parties are negotiating over a new agreement through
Section 6 procedures, see id., or where the employer attempts to unilaterally alter the agreement
Association, Local 158 v. Toledo Lakefront Dock Co., 1977 WL 1809, at *3 (N.D. Ohio Dec. 16,
1977)(finding a "major" dispute where employer attempted to abrogate the contractual arbitration
procedure, because such an action was not a matter of contract interpretation, but an attempt to
Federal District Courts have the power to enforce the duty to maintain the status quo and
enjoin either party from engaging in conduct that violates that duty. Detroit & T.S.L.R.R., 396
U.S. 142 (1969). The RLA's status quo requirement is "central to its design. Its immediate effect
is to prevent the Union from striking and management from doing anything that would justify a
strike." Id. at 150. Pursuant to Section 6 of the RLA, the section of immediate concern in this
case, provides that "rates of pay, rules, or working conditions shall not be altered" during the period
from the first notice of a proposed change in agreements up to and through any proceedings before
the National Mediation Board. Id. Because one party may wish to change the status quo without
undue delay, the power granted in the RLA to the other party "to preserve the status quo for a
prolonged period" encourages the moving party to compromise and reach agreement without
interrupting commerce. Id. Injunctive relief may issue, even in the absence of a traditional
during a "major" dispute is a violation of the status quo under the RLA. See, e.g., International
Brotherhood of Teamsters (Airline Division) v. Texas International Airlines, Inc., 717 F.2d 157,
160-61 (5th Cir. 1983)(holding that illegality of unilaterally amending or modifying the terms of
In this case, Southwest Airlines has repeatedly violated the RLA's requirement that
Defendant maintain the parties' status quo. Southwest Airlines has continuously failed to uphold
its duty to bargain and negotiate regarding: (1) the unilaterally implemented an Infectious Disease
Control Policy, (2) the Emergency Extended Time Off ("ExTO") Program, (3) COVID quarantine
policies, (4) the Vaccine Participation Pay Program ("VPPP"), (5) the Flight Crew Training
Instructors Program, and (6) the mandatory COVID vaccine policy. Each of these new unilaterally
developed and established policies was rolled out by Southwest Airlines without negotiations or
bargaining. Each new policy violates the parties' status quo and is an issue within a major dispute
that requires Southwest Airlines to maintain the parties' status quo while negotiating with
SWAPA. Instead, Southwest Airlines is acting as if it has a force majeure provision within the
parties' collective bargaining agreement ("CBA") when it does not. Without court intervention,
The unilaterally implemented Infectious Disease Control Policy impacts the parties' status
quo by altering the Pilots' pay, rules, or working conditions. Specifically, this new policy
instituted quarantine and pay changes (APP 28) which required Pilots to quarantine under certain
circumstances and it also impacted Pilot's pay as it issued a new pay policy for time spent in
quarantine. This new unilateral policy was not bargained upon by Defendant Southwest Airlines
before it was issued. SWAPA did not push back on this policy at the time because the pay language
within the policy indicated that no pay would be lost due to the quarantine.
The unilaterally implemented ExTO Program impacts the parties' status quo by altering
the Pilots' pay, rules, or working conditions. This new program directly offered Pilots the option
to not fly and not be paid in contravention of the terms and conditions of the CBA. Pilots are paid
for their flying and are guaranteed contractual minimum pay if flying is taken away from them.
(See CBA provisions within Section 4 and Section 4 H. APP 80-101, APP 84) Southwest Airlines'
unilateral offer – directly to Pilots - of this extended "time off" with reduced pay program, was not
bargained upon by Defendant and Defendant would not agree to reach an Memorandum of
The unilaterally implemented COVID quarantine policies impacts the parties' status quo
by altering the Pilots' pay, rules, or working conditions. The Company's unilaterally created
policy for quarantines and pay during quarantines was unilaterally altered by the Company in June
of 2021 by Defendant removing language within the policy which placed an affirmative duty to
pay employees for time spent in quarantine (see APP 28) to wholly discretionary language stating
that the Company "may" pay the employee for quarantines imposed by the Company (see APP
31). Again, Pilots are paid for their flying and guaranteed contractual minimum pay if flying is
taken away from them. There is no contractual right vested in the Company to create a policy that
reduces Pilot guaranteed pay. (See CBA provisions within Section 4 and Section 4 H. APP 80-
101, APP 84). This unilateral shift by the Company does not comport with the parties' CBA and
The unilaterally implemented VPPP policy impacts the parties' status quo by altering the
Pilots' pay, rules, or working conditions. Specifically, this policy which was unilaterally
implemented by Defendant after this lawsuit was filed by SWAPA, directly changes the pay of
Pilots by offering them 16 hours or 13 trip pulls (a unit of Pilot pay), if they undertake certain
vaccine-related actions. It also takes away Pilot pay for those Pilots who chose to not participate
in this program, whether or not they are in fact vaccinated. The unilateral changing of the Pilots'
pay clearly violates the parties' status quo and Southwest Airlines' refusal to reach a memorandum
of understanding demonstrates its cavalier attitude in which it believe that it does not need to
The unilaterally implemented Flight Crew Training Instructors Program impacted the
parties' status quo by altering the Pilots' pay, rules, or working conditions. With this program,
Southwest Airlines unilaterally rolled out a new program to train pilots to be Flight Crew Training
Instructors (APP 13). This newly created program literally took work from one union (TWU 557)
and assigned it to pilots within SWAPA. (APP 13) Defendant solicited Pilots to work in this new
category of Pilots, offering them different work and pay. After unilaterally rolling this policy out,
Southwest Airlines admitted that this new job function would change the pay, rules, and working
conditions of the Pilots selected for this position. This action again violated the parties' status
quo. This Instructor Program was implemented without negotiations with SWAPA. After the
Instructor Program was rolled out, SWAPA was able to negotiate a tentative agreement with the
Company that is, at the time of this writing, pending approval by the SWAPA Board of Directors
Finally, not only does the newly implemented unilateral mandatory COVID vaccine policy
impact the parties' status quo by altering the Pilots' pay, rules, or working conditions, it also is a
work rule mandate that requires decision and effects negotiations under the RLA. This new policy
announced by Southwest Airlines on October 4, 2021, purports to require all Pilots to be vaccinated
by certain dates, submit proof of vaccination by certain dates, or be terminated. This radical new
policy is in stark contrast with the progressive discipline and termination policies within the
It is anticipated that Southwest Airlines will attempt to argue that this is a "minor" dispute
rather than a major dispute. Such argument is not supportable because there is no contractual term
that provides Southwest Airlines the right to unilaterally alter "rates of pay, rules, or working
conditions" during the parties' Section 6 negotiations. "The [RLA's] status quo requirement is
central to its design." Detroit & T. S. L. R. Co. v. United Transp. Union, 396 U.S. 142, 150 (1969).
The status quo of, "the actual, objective working conditions out of which the dispute arose,
irrespective of whether these conditions are covered in an existing collective agreement," must be
maintained by Southwest Airlines. Id. at 143. Southwest Airlines cannot unilaterally alter the
rates of pay, rules, or working conditions and doing so is a major dispute because the status quo
Southwest Airlines may attempt to argue that COVID has created a situation that requires
it to take unilateral actions to ensure the safety and health of its employees and passengers. The
primary problem with this argument is that Southwest Airlines does not have a force majeure
clause within the Parties' CBA and it cannot unilaterally create one. Indeed, Southwest has
attempted to obtain a force majeure provision in past negotiations, and it has not succeeded and
there is no such term in the parties' CBA. Additionally, Southwest Airlines cannot establish that
it took every reasonable effort to attempt to negotiate regarding the "rates of pay, rules, or working
conditions" before it unilaterally made the changes complained of in this litigation. Southwest
Airlines also cannot establish, at all, that bargaining with the Union, as required by the RLA, would
have negatively impacted public safety. Indeed, the unilaterally rolled out ExTO program is
similar to the ETO program, and the Company was able to negotiate with and reach a
Memorandum of Understanding with SWAPA regarding the ETO program. There is simply no
reason, other than anti-Union animus and Defendant's "might makes right" attitude which have
prevented Southwest Airlines from complying with the requirements of the RLA.
Southwest Airlines may argue that the CBA's "management right's" provision (APP 63)
gives it the right to do what it has done (and what is complained about by SWAPA in this
litigation). Such an argument would fail. The management rights provision of the parties contract
does not support Defendant's actions. This clause of the parties' CBA states:
The right to manage and direct the work force, subject to the provisions of this
Agreement, is vested in the Company. Employees covered by this Agreement shall be
governed by all Company rules, regulations and orders previously or hereafter issued by
proper authorities of the Company which are not in conflict with the terms and
conditions of this Agreement and which have been made available to the affected
employees and the Association prior to becoming effective.
(APP 63, emphasis added). Creating new programs and policies, such as the mandatory vaccine
policy, which includes a new non-just cause standard for termination of pilots, is clearly in conflict
with the terms and conditions of the parties CBA. As held by the Supreme Court, "In a situation
in which a party asserting a contractual basis for its claim is 'insincere' in so doing, or its 'position
[is] founded upon insubstantial grounds,' the result of honoring that party's characterization would
be to undercut 'the prohibitions of § 2, Seventh, and § 6 of the Act' against unilateral imposition
Association, 491 U.S. 299, 306 (1989)(emphasis added). Here, it would be insincere and frivolous
for Southwest Airlines to argue that it has Management Rights to alter the rates of pay, rules, and
working conditions of SWAPA Pilots as it has done in the past several months. While COVID is
a serious issue, COVID does not obviate Defendant's RLA imposed obligations to negotiate with
SWAPA and to maintain the parties' status quo during the negotiations.
Furthermore, even if Southwest Airlines argues that its actions are within its management's
rights because its actions arguendo do not conflict with the terms and conditions of the CBA, the
Supreme Court has long held that, "that what must be preserved as the status quo are the actual,
objective working conditions out of which the dispute arose, irrespective of whether these
conditions are covered in an existing collective agreement. Detroit & T. S. L. R. Co. v. United
Transp. Union, 396 U.S. 142, 143 (1969). Southwest simply cannot do as it pleases without
involving SWAPA in the process and negotiating with SWAPA regarding any change that impacts
the Pilots' rates of pay, rules, or working conditions. Here, this major dispute has reached a point
wherein Defendant has repeatedly, and with increasing frequency, violated the parties' status quo
The element of irreparable harm need not be shown in the context of a court injunction to
enforce the statutory requirements of the RLA. Even though SWAPA need not establish
irreparable harm, without an injunction the Union and its members will be irreparably harmed to
be sure.
What is happening in this case is very simple. Southwest Airlines is in year two of direct
contract negotiations with SWAPA and Southwest Airlines is engaged in bad faith negotiations in
an effort to damage the strength of the Union and weaken the Union's bargaining position. Each
time that the Company unilaterally rolls out a new program or policy that impacts the parties'
status quo, SWAPA is in a fire drill response mode because of the Company's violations of the
RLA. SWAPA must send a cease and desist letter which the Company promptly ignores and then
SWAPA must answer a flood of questions and worry by its members who have a CBA that is
being unilaterally altered and ignored by the Company. Each time this happens, turmoil and labor
strife increases. Each time this happens, the Company is flexing its muscle in violation of the RLA
in an effort to damage the Union. And the Union is being damaged. The Union is having to use
internal resources to respond and put out this fire each time it happens. Discord among Union
members and employees grows each time this happens. The drafters of the RLA were attempting
to prevent this labor strife, but Southwest Airlines acts as if it is above the RLA.
Worth noting, this is not happening at other airlines and Southwest Airlines is an outlier
within the domestic industry. A direct comparison can be made to American Airlines, and its
14,000 pilots represented by the Allied Pilots Association ("APA"). (Myers Declaration ¶1, APP
285) The APA has successfully negotiated and bargained with American Airlines regarding pilot
working conditions, work rules, pay, and benefits during COVID while the parties have been in
Section 6 negotiations. (Myers Declaration ¶3-5, APP 286) APA has entered into nine separate
MOUs regarding COVID related programs that would have altered the parties' status quo if
American Airlines had not negotiated with and reached agreement with APA as required under the
RLA. (Myers Declaration ¶5-6, APP 286-7). The MOUs reached by American Airlines and APA
are also similar in nature to those at issue in this case. (See APA and American Airlines letters of
For the reasons stated above, the Court should issue temporary, preliminary, and permanent
K. Helen Yu
Texas State Bar No. 24071565
Southwest Airlines Pilots Association
1450 Empire Central Drive,
Suite 737
Dallas, TX 75247
Phone: (214) 722-4256
Fax (214) 351-2504
The undersigned hereby certifies that counsel for SWAPA, Hal K. Gillespie, has conferred
with counsel for Southwest Airlines, Jonathan C. Fritts, on October 8, 2021 regarding the above
and foregoing. The relief sought by SWAPA within this brief and its related motion is opposed
by Southwest Airlines.
The undersigned hereby certifies that a copy of the forgoing document has been served
upon counsel of record for Southwest Airlines by and through the Court's ECF system on October
6, 2021.


text:
Ecological monitoring of genetically modified crops : a workshop summary
Crops Plant genetics Plant population genetics Plant genetic engineering Transgenic plants TECHNOLOGY & ENGINEERING Plants, Genetically Modified Crops, Agricultural Ecosystem sähkökirjat
National Academy Press 2001EISBN 9780309513425
On July 13-14, 2000, the National Research Council held a workshop on ecological monitoring of genetically modified crops. The workshop specifically excluded monitoring aimed at detecting effects on human health. Its focus was on monitoring for effects that genetically modified crops might have on the surrounding ecosystems, including plants, animals, and microorganisms. The purpose was to lay out the issues surrounding such monitoring, to describe what was known, and to identify what needed further attention.


text:
Black History Month Storytelling for children and families.
Enjoy storytelling for the family and children through honoring the achievements, adversities, and legacy of African Americans in the United States. Celebrate these voices and achievements through storytelling and a book display with love and joy. Reflect on shared history of the impact of Black Historical figures and pioneers.
AGE GROUP: | Toddlers | Kids | Families | Adults |
EVENT TYPE: | Story Time |
|Mon, Mar 27
|12:00PM to 8:00PM
|Tue, Mar 28
|10:00AM to 6:00PM
|Wed, Mar 29
|12:00PM to 8:00PM
|Thu, Mar 30
|10:00AM to 6:00PM
|Fri, Mar 31
|10:00AM to 6:00PM
|Sat, Apr 01
|10:00AM to 6:00PM
|Sun, Apr 02


text:
For the third time in as many years, a Silicon Valley tech company has brought workers to the United States and paid them in foreign currency in violation of state and federal law. On April 29, a federal judge ordered Fremont electronics manufacturer BiTMICRO Networks to pay 18 Filipino workers a total of $161, 268 in wages and penalties.
The company had brought the workers from its Philippine subsidiary to work in the U.S. on a temporary B1 visa and paid them in pesos at the wage they earned in the Philippines — the equivalent of $1.66 per hour. The workers, who worked an average of 57 hours per week, received no overtime.
The B1 visa is the same one that Tesla contractors used to unlawfully obtain Eastern Europe construction workers and pay them the equivalent of $5 per hour, as reported in Sunday's Mercury News expose.
California has strong laws and hefty penalties, but clearly they did not deter BitMICRO. Michael Eastwood of the Department of Labor in San Jose said it "shocks the conscience that high tech companies in the Silicon Valley are paying workers less than $2 per hour."
The Santa Clara County Wage Theft Coalition, of which I am a member, seeks to have district attorneys prosecute egregious or repeat wage theft violators.
BitMICRO's egregious conduct followed on the heels of similar conduct by two other companies. In 2014, EFI, a Fremont company, flew technicians from its Bangalore, India office for technology installation. They paid the workers about $1.21 per hour in Indian rupees for 122 hours of work per week in conditions Eastwood called "worse than anything I ever saw in any of those Los Angeles sweatshops."
In 2013, Sunnyvale-based Bloom Energy brought workers from Mexico to refurbish its clean energy power generators, paying them the equivalent of $2.66 per hour in Mexican pesos. Bloom contracts with giant corporations as well as with Santa Clara County.
The specter of criminal prosecution would have deterred EFI, Bloom Energy, BiTMICRO and even Tesla.
Garden variety wage theft — failure to pay overtime or minimum wage — has reached epidemic proportions in Silicon Valley and has become a business model for far too many industries such as restaurants, construction and care homes.
Often they don't even pay wage theft judgments because there are no legal or business consequences. To combat this problem, a growing number of jurisdictions are refusing to contract with or issue licenses or permits to companies that do not pay court ordered judgments.
Santa Clara County and the Santa Clara Unified School District recently enacted policies that require bidders and contractors to disclose wage-theft judgments, giving them the power to refuse to contract with violators that haven't paid judgments.
On May 24, the San Jose City Council will vote on the same policy and an ordinance that would empower the city to withhold the tools many companies need to operate — contracts or permits — if they do not pay judgments. The city must approve this wage-theft policy and ordinance.
But even if companies do pay, as did BiTMICRO, EFI, and Bloom Energy, companies who engage in similar egregious or repeated wage theft practices should face criminal prosecution.
We must make wage theft in Silicon Valley and failure to pay wage theft judgments a costly choice. There must never be another BitMICRO, EFI, Bloom Energy or — whether or not it directly broke the law — Tesla.
Ruth Silver Taube is supervising attorney of the Katharine & George Alexander Community Law Center at the Santa Clara University School of Law. She wrote this for the Mercury News.