Lihli Fashions Corp., Inc. v. Nat'l Labor Relations Bd., 80 F.3d 743 (2d Cir. 1996). · Go Syfert
Lihli Fashions Corp., Inc. v. Nat'l Labor Relations Bd., 80 F.3d 743 (2d Cir. 1996). Cases Citing This Book View Copy Cite
“the parties concede that the sales and marketing employees of lihli, inc. do not constitute an appropriate bargaining unit with the production, maintenance, packing, and shipping employees of liyan.”
232 citation events (196 in the last 25 years) across 16 distinct courts.
Strongest positive: Kilkenny, as Trustees of the Construction Council Local 175 Annuity Fund v. Manco Enterprises, Inc. (nyed, 2023-03-31)
Treatment trajectory · 1996 → 2026 · click a year to view as-of
1996 2011 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
examined Cited as authority (verbatim quote) Kilkenny, as Trustees of the Construction Council Local 175 Annuity Fund v. Manco Enterprises, Inc. (9×) also: Cited as authority (rule), Cited "see"
E.D.N.Y · 2023 · signal: cf. · quote attribution · 1 verbatim quote · confidence high
the parties concede that the sales and marketing employees of lihli, inc. do not constitute an appropriate bargaining unit with the production, maintenance, packing, and shipping employees of liyan.
discussed Cited as authority (rule) Davis v. 2192 Niagara Street, LLC (2×) also: Cited "see"
W.D.N.Y. · 2025 · confidence medium
See Perez Perez v. Escobar Construction, Inc., 2024 WL 3594325 , at * 4 (2d Cir. July 31, 2024) (summary order) (considering “the totality of the circumstances” and concluding that multiple corporate entities were, under the FLSA, a single employer because the corporate entities shared staff and work sites, paid employees from the same accounts belonging to all three entities, collectively advertised, and were controlled by the same person); Lihli Fashion Corp., Inc., 80 F.3d at 747 (whether separate companies are a single employer depends on the totality of the circumstances and is charac…
discussed Cited as authority (rule) Gesualdi v. Advanced Ready Mix Corp. (2×)
E.D.N.Y · 2025 · confidence medium
Employers that are determined to be alter egos, or to function as a single employer/single unit, are “jointly and severally liable for each other’s debts and obligations, including financial obligations under [a] collective bargaining agreement.” Lihli Fashions Corp., Inc. v. N.L.R.B., 80 F.3d 743, 748 (2d Cir.1996).
cited Cited as authority (rule) Spears v. Damen Healthcare Group, LLC
N.D. Ill. · 2025 · confidence medium
Ultimately, “single employer status . . . is characterized by the absence of an arm’s length relationship.” Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir. 1996) (cleaned up).
discussed Cited as authority (rule) Natale v. Allied Aviation Services, Inc (2×)
S.D.N.Y. · 2024 · confidence medium
“Separate companies are considered a single employer if they are part of a single integrated enterprise.” Lihli Fashions, 80 F.3d at 747 (quotation marks omitted).
examined Cited as authority (rule) Cement and Concrete Workers District Council Welfare Fund v. Manny P. Concrete Co., Inc. (4×) also: Cited "see, e.g."
E.D.N.Y · 2023 · confidence medium
Kilkenny, 2023 WL 2734805 , at *4 (citing Lihli, 80 F.3d at 748).
discussed Cited as authority (rule) KNOWLES v. ROSA MOSAIC AND TILE COMPANY (2×) also: Cited "see, e.g."
S.D. Ind. · 2023 · confidence medium
"Ultimately, single employer status . . . is characterized by the absence of an arm's length relationship found among unintegrated companies." Id. at 947 (quoting Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir. 1996)).
examined Cited as authority (rule) Trustees of the Local 7 Tile Industry Welfare Fund v. Castle Stone and Tile, Inc. (3×) also: Cited "see"
E.D.N.Y · 2022 · confidence medium
But “not every factor need be pre- sent, and no particular factor is controlling.” Lihli Fashions, 80 F.3d at 747.
examined Cited as authority (rule) Granda Chica v. Shallu Construction Corp. (3×) also: Cited "see"
E.D.N.Y · 2022 · confidence medium
Ultimately, single employer status depends on all the circumstances of the case and is characterized by absence of [the] arm’s length relationship found among unintegrated companies.” Lihli Fashions Corp., 80 F.3d at 747 (internal quotation marks and citations omitted); see also Chen v. TYT East Corp., No. 10-CV-5288 (PAC), 2012 WL 5871617 , at *3 (S.D.N.Y.
cited Cited as authority (rule) NLRB v. Newark Electric
2d Cir. · 2021 · confidence medium
Lihli Fashions Corp., 80 F.3d at 747.
cited Cited as authority (rule) Chan v. Queens Blossom Corp.
E.D.N.Y · 2021 · confidence medium
Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir. 1996).
discussed Cited as authority (rule) Trustees of the Local 7 Tile Industry Welfare Fund v. Castle Stone and Tile, Inc. (2×)
E.D.N.Y · 2020 · confidence medium
Courts consider several non-dispositive factors in determining whether two entities are a single employer: “interrelation of op- erations, common management, centralized control of labor relations[,] and common ownership.” Lihli Fashions, 80 F.3d at 747; see also Radio & Television Broad.
examined Cited as authority (rule) Division 1181 Amalgamated Transit Union - New York Employees Pension Fund v. Canal Escorts, Inc. (4×) also: Cited "see"
E.D.N.Y · 2020 · confidence medium
Of particular significance in this case, as discussed below, “[i]f two companies are deemed alter egos of each other, then each is bound by the collective bargaining agreements signed by the other.” Lihli Fashions Corp., Inc. v. N.L.R.B. (“Lihli”), 80 F.3d 743, 748 (2d Cir. 1996).
discussed Cited as authority (rule) Hines v. JBR Trucking LLC
C.D. Ill. · 2020 · confidence medium
“Ultimately, single employer status . . . is characterized by the absence of an arm’s length relationship found among unintegrated companies.” Lippert Tile Co., 724 F.3d at 947 (quoting Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir. 1996)).
discussed Cited as authority (rule) Moore v. New York Concrete Corporation
S.D.N.Y. · 2020 · confidence medium
Fund v. Express Servs., Inc., 426 F.3d 640 , 650 (2d Cir. 2005) (no shared business purpose where companies “engaged in different, though related, lines of business within the freight transportation industry”), and Lihli Fashions Corp., 80 F.3d at 749 (no shared business purpose where one entity manufactured clothing and the other sold and marketed it).
cited Cited as authority (rule) Ferrara v. Happy Time Trucking LLC
E.D.N.Y · 2020 · confidence medium
Rather, something more must be shown.” Id. at 748.
discussed Cited as authority (rule) Bricklayers Insurance and Welfare Fund v. Mastercraft Masonry I, Inc.
E.D.N.Y · 2020 · confidence medium
That doctrine considers “[s]eparate companies . . . a ‘single employer’ if they are ‘part of a single integrated enterprise.’” See Lihli Fashions Corp. Inc. v. N.L.R.B., 80 F.3d 743, 747 (2d Cir. 1996) (quoting Clinton’s Ditch Coop.
discussed Cited as authority (rule) Rochester Laborers' Welfare-S.U.B. Fund by Robert Brown as Chairman, and Daniel Hogan as Secretary v. Akwesasne Construction Inc.
W.D.N.Y. · 2019 · confidence medium
Lihli Fashions Corp., 80 F.3d at 748 (The “hallmarks of the alter ego doctrine include whether the two enterprises have 2 The only potential factual point of dispute is when Akwesasne commenced operations.
examined Cited as authority (rule) Div. 1181 A.T.U.-n.Y. Emps. Pension Fund v. City of N.Y. (3×)
2d Cir. · 2018 · confidence medium
Accepting, as we must, all of the Fund's nonconclusory allegations as true, we conclude that it has not pleaded DOE involvement to a degree that would suggest that the DOE and the Contractors were "a single integrated enterprise." 5 Lihli Fashions , 80 F.3d at 747 (quotation marks omitted).
examined Cited as authority (rule) Div. 1181 A.T.U.—N.Y. Emps. Pension Fund v. City of N.Y. Dep't of (3×)
2d Cir. · 2018 · confidence medium
As to the common management factor, the Fund cites contractual 15 provisions prohibiting the Contractors from replacing their Chief Executive 16 Officers or effecting a significant change in ownership without DOE approval. 17 But these contractual provisions, typical in commercial contracts, do not 18 plausibly suggest that the DOE and the Contractors had a common management 17 1 structure, especially where, as here, the contracts also contained an express 2 conflict‐of‐interest clause that prohibited DOE officers and employees from 3 serving on the board of any Contractor. 4 Accepting, as…
discussed Cited as authority (rule) Moore v. Navillus Tile, Inc.
S.D.N.Y. · 2017 · confidence medium
On the other hand, companies have been found to have “completely different” business purposes where, for example, one company manufactures clothing and another markets and sells clothing, Lihli Fashions Corp., 80 F.3d at 749, or where the companies “were engaged in different, though related, lines of business within the freight transportation industry,” N.Y.
discussed Cited as authority (rule) Trustees of the Mosaic & Terrazzo Welfare, Pension, Annuity & Vacation Funds v. High Performance Floors, Inc. (2×)
E.D.N.Y · 2017 · confidence medium
If entities are determined to be alter egos of each other, “ ‘then each is bound by the collective bargaining agreements signed by the other,’ and ‘thereby obligated to honor the pension [and welfare benefit] contributions terms’ of the agreement.” Plumbers, Pipefitters and Apprentices Local Union No. 112 Pension, Health and Educational and Apprenticeship Plans v. Mauro’s Plumbing, Heating and Fire Suppression, Inc. (“Mauro’s Plumbing”), 84 F.Supp.2d 344, 349 (N.D.N.Y. 2000) (quoting Lihli Fashions Corp., Inc. v. N.L.R.B., 80 F.3d 743, 748 (2d Cir. 1996)).
discussed Cited as authority (rule) Mason Tenders District Council of Greater New York v. Phase Construction Services, Inc.
S.D.N.Y. · 2016 · confidence medium
Similarly, to state a claim under the single employer theory of liability, Plaintiffs must allege sufficient facts to show, among other things, an “interrelationship of operations, common management, centralized control of labor relations and common ownership,” as well as “the use of common office facilities and equipment and family connections between or among the various enterprises.” Lihli Fashions Corp. Inc. v. N.L.R.B., 80 F.3d 743, 747 (2d Cir. 1996) (citing Radio & Television Broadcast Tech.
discussed Cited as authority (rule) Trustees of Laborers Union Local No. 1298 v. A to E, Inc.
E.D.N.Y · 2014 · confidence medium
Under the single employer doctrine, separate companies will be jointly and severally liable under a collective bargaining agreement signed by the other if they are part of a “single integrated enterprise.” Lihli Fashions Corp., Inc. v. N.L.R.B., 80 F.3d 743, 747-48 (2d Cir.1996) (holding that the status of two companies as a single employer “is enough to hold them jointly and severally liable for each other’s debts and obligations, including financial obligations under [a] collective bargaining agreement,” even if the non-signatory may not be bound by the agreement); Ferrara v. Oakfi…
examined Cited as authority (rule) Ferrara v. Smithtown Trucking Co. (3×) also: Cited "see, e.g."
E.D.N.Y · 2014 · confidence medium
Single Employer Doctrine The single employer and alter ego doctrines are “conceptually distinct.” Lihli Fashions Corp., Inc. v. N.L.R.B., 80 F.3d 743, 748 (2d Cir.1996) (quoting Truck Drivers Local Union No. 807 v. Regional Import & Export Trucking Co., 944 F.2d 1037, 1046 (2d Cir.1991)).
discussed Cited as authority (rule) Grodotzke v. Seaford Avenue Corp.
E.D.N.Y · 2014 · confidence medium
To determine whether separate companies are a “single employer,” courts apply a four-factor test The test analyzes the “‘interrelation of operations, common management, centralized control of labor relations and common ownership.’ ” Lihli Fashions Corp., Inc. v. N.L.R.B., 80 F.3d 743, 747 (2d Cir.1996) (quoting Radio & Television Broad.
discussed Cited as authority (rule) United Union of Roofers, Waterproofers, & Allied Workers Local No. 210 v. A.W. Farrell & Son, Inc. (2×)
2d Cir. · 2013 · confidence medium
We have added two additional factors: (5) “the use of common office facilities and equipment,” and (6) “family connections between or among the various enterprises.” Lihli Fashions Corp. v. NLRB, 80 F.3d at 747 (explaining that single employer status is characterized by absence of arm’s length relationship between companies).
discussed Cited as authority (rule) Lippert Tile Co. v. International Union of Bricklayers & Allied Craftsmen
7th Cir. · 2013 · confidence medium
“No one of these factors is conclusive; instead, the decision- *947 maker must weigh the totality of the circumstances.” Id. “ ‘Ultimately, single employer status ... is characterized by the absence of an arm’s length relationship found among unintegrated companies.’ ” Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir.1996) (citation omitted).
discussed Cited as authority (rule) Turley v. ISG Lackawanna, Inc.
W.D.N.Y. · 2013 · confidence medium
While “not every factor need be present, and no particular factor is controlling,” Lihli Fashions Corp., Inc. v. N.L.R.B., 80 F.3d 743, 747 (2d Cir.1996), the second factor — centralized control of labor relations — is the most significant.
examined Cited as authority (rule) Ferrara v. Oakfield Leasing Inc. (6×) also: Cited "see"
E.D.N.Y · 2012 · confidence medium
Under the single employer doctrine, two nominally distinct enterprises will be joint and severally liable under the CBA signed by only one when the two act as a “single integrated enterprise.” Lihli, 80 F.3d at 747; see Labarbera v. Cretty Enterprises, Inc., Nos. 03 Civ. 6112, 04 Civ. 5178, 2007 WL 4232765 , at *5 (E.D.N.Y.
examined Cited as authority (rule) Lippert Tile Co. v. International Union of Bricklayers & Allied Craftsmen District Council of Wisconsin Local 5 (3×) also: Cited "see, e.g."
E.D. Wis. · 2012 · confidence medium
Applying this doctrine to the present case, I conclude that, although the Lippert Group and DeanAlan did not sign the CBA, they are bound by the arbitration agreement contained in the CBA if they and Lippert Tile, which did sign the CBA, constitute a “single employer.” To determine whether two companies constitute a single employer, I ask whether they have the type of arm’s length relationship that ordinarily exists between unintegrated entities, Likli Fashions, 80 F.3d at 747 (2d Cir.1996), and I consider four factors: (1) common ownership, (2) centralized control over labor relations, …
discussed Cited as authority (rule) Carnival Carting, Inc. v. National Labor Relations Board
2d Cir. · 2012 · confidence medium
To determine single employer status, we consider four factors: (1) “interrelation of operations,” (2) “common management,” (3) “centralized control of labor relations,” and (4) “common ownership.” Id. at 747. *23 “[N]ot every factor need be present [for single employer status to attach], and no particular factor is controlling.
discussed Cited as authority (rule) New York State Teamsters Conference Pension and Retirement Fund v. DOREN AVE. ASSOCIATES, INC.
N.D.N.Y. · 2004 · confidence medium
Relevant are whether the companies in question have “substantially identical management, business purpose, operation, equipment, customers, supervision, and ownership.” Lihli Fashions, 80 F.3d at 748.
examined Cited as authority (rule) Bricklayers & Allied Craft-Workers Local 2 v. C.G. Yantch, Inc. (3×)
N.D.N.Y. · 2003 · confidence medium
The Second Circuit, in Lihli Fashions, added to this list the factors of whether the companies utilize common office facilities and equipment, and whether there exists a family relationship between the enterprises. 80 F.3d at 747.
cited Cited as authority (rule) Martinez v. Caravan Transportation, Inc.
E.D.N.Y · 2003 · confidence medium
Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir.1996). 16 .
examined Cited as authority (rule) National Labor Relations Board v. G&t Terminal Packaging Co., Inc., Mr. Sprout, Inc., Chain Trucking, Inc., Tray Wrap, Inc., and Slow Pack, Inc. (6×) also: Cited "see", Cited "see, e.g."
2d Cir. · 2001 · signal: cf. · confidence medium
Evidence that a desire to avoid union obligations motivated the formation of a corporation may also be relevant to a finding of alter ego status, but a finding of “anti-union motivation is [not] necessary.” Goodman Piping, 741 F.2d at 12 ; cf. Lih-li Fashions, 80 F.3d at 748 (explaining that “focus” of alter ego inquiry is on whether there was an intent to avoid union obligations).
discussed Cited as authority (rule) International Oil, Chemical & Atomic Workers, Local 7-517, and International Oil, Chemical & Atomic Workers, International, Afl-Cio v. Uno-Ven Company
7th Cir. · 1999 · confidence medium
For the general approach, see Papa v. Katy Industries, Inc., 166 F.3d 937 (7th Cir.1999), and for its application in labor *782 cases see, e.g., Howard Johnson Co. v. Detroit Local Joint Executive Board, supra, 417 U.S. at 259 n. 5, 94 S.Ct. 2236 ; Trustees of Pension, Welfare & Vacation Fringe Benefit Funds v. Favia Electric Co., 995 F.2d 785 , 788-89 (7th Cir.1993); Esmark, Inc. v. NLRB, supra; Lihli Fashions Corp. v. NLRB, 80 F.3d 743, 748-49 (2d Cir.1996) (per curiam); New England Mechanical, Inc. v. Laborers Local Union 294, supra, 909 F.2d at 1343 .
discussed Cited as authority (rule) Carner v. MGS-576 5th Ave. Inc. (2×)
S.D.N.Y. · 1998 · confidence medium
The determination of single employer status is a question of fact. *350 See, Lihli Fashions Corp., Inc. v. N.L.R.B., 80 F.3d 743, 747 (2d Cir.1996).
discussed Cited as authority (rule) Carner v. MGS-576 5th Ave. Inc. (2×)
S.D.N.Y. · 1997 · confidence medium
The determination of single employer status is a question of fact. see, Lihli Fashions Corp., Inc. v. N.L.R.B., 80 F.3d 743, 747 (2d Cir.1996).
cited Cited as authority (rule) Bourgal v. Robco Contracting Enterprises, Ltd.
E.D.N.Y · 1997 · confidence medium
Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir.1996); Goodman Piping Prods., Inc. v. NLRB, 741 F.2d 10, 11 (2d Cir.1984).
cited Cited as authority (rule) Rivera v. Puerto Rican Home Attendants Services, Inc.
S.D.N.Y. · 1996 · confidence medium
Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir.1996).
cited Cited "see" Demopoulos v. F&B Fuel Oil Co. Inc.
S.D.N.Y. · 2023 · signal: see · confidence high
See Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir. 1996) (internal quotations and citations omitted).
cited Cited "see" Demopoulos v. F&B Fuel Oil Co. Inc.
S.D.N.Y. · 2022 · signal: see · confidence high
See Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 747 (2d Cir. 1996) (internal quotations and citations omitted).
cited Cited "see" Turley v. ISG Lackawanna, Inc.
2d Cir. · 2014 · signal: see · confidence high
See, 12 e.g., Lihli Fashions Corp. v. Natʹl Labor Relations Bd., 80 F.3d 743 , 748 (2d Cir. 13 1996); Trustees of Pension, Welfare & Vacation Fringe Benefit Funds of IBEW 14 Local 701 v. Favia Elec.
discussed Cited "see" Trustees of the New City District Council of Carpenters Pension Fund v. Integrated Structures Corp.
2d Cir. · 2014 · signal: see · confidence high
Id. at 286; see Lihli Fashions Corp. v. NLRB, 80 F.3d 743 , 748 (2d Cir.1996) (per curiam) (“The focus of the alter ego doctrine ... is on the existence of a disguised continuance or an attempt to avoid the obligations of a collective bargaining agreement through a sham transaction or technical change in operations.” (internal quotation marks omitted)).
discussed Cited "see" Metal Lathers Local 46 Pension Fund v. River Avenue Contracting Corp.
S.D.N.Y. · 2013 · signal: see · confidence high
See Lihli Fashions Corp., Inc. v. N.L.R.B., 80 F.3d 743, 748 (2d Cir.1996) (per curiam) (“If two companies are deemed alter egos of each other, then each is bound by the collective bargaining agreements signed by the other.”).
discussed Cited "see" Solis v. Loretto-Oswego Residential Health Care Facility
2d Cir. · 2012 · signal: see · confidence high
See Lihli Fashions Corp. v. NLRB, 80 F.3d 743 , 747 (2d Cir.1996) (per curiam) (NLRA); Cook v. Arrowsmith Shelburne, Inc., 69 F.3d 1235, 1240 (2d Cir.1995) (Title VII); Parker v. Columbia Pictures Indus., 204 F.3d 326 , 341 (2d Cir.2000) (ADA).
discussed Cited "see" Fowler v. SCORES HOLDING COMPANY, INC.
S.D.N.Y. · 2009 · signal: see · confidence high
See Lihli Fashions Corp. v. NLRB, 80 F.3d 743 , 747 (2d Cir.1996); Clinton’s Ditch Co-op Co., Inc. v. NLRB, 778 F.2d 132 , 136 (2d Cir.1985); Dias, 2009 WL 595601 , at *6; Niland v. Buffalo Laborers Welfare Fund, No. 04 Civ. 0187F, 2007 WL 3047099 , at *6 (W.D.N.Y.
cited Cited "see" New York District Council of Carpenters Pension Fund v. Perimeter Interiors, Inc.
S.D.N.Y. · 2009 · signal: see · confidence high
See Lihli Fashions Corp., Inc. v. NLRB, 80 F.3d 743, 748 (2d Cir.1996).
cited Cited "see" National Labor Relations Board v. 675 West End Owners Corp.
2d Cir. · 2008 · signal: see · confidence high
See Lihli Fashions Corp., 80 F.3d at 747.
Retrieving the full opinion text from the archive…
Lihli Fashions Corporation, Inc. King Kuo International Enterprises Inc. Lihli of New York, Inc. And Liyan International, Inc.
v.
National Labor Relations Board, International Ladies Garment Workers Union, Local 89-22-1, Intervenor
1042.
Court of Appeals for the Second Circuit.
May 9, 1996.
80 F.3d 743
Cited by 30 opinions  |  Published

80 F.3d 743

151 L.R.R.M. (BNA) 2941, 131 Lab.Cas. P 11,544

LIHLI FASHIONS CORPORATION, INC.; King Kuo International
Enterprises Inc.; Lihli of New York, Inc.; and
Liyan International, Inc., Petitioners,
Cross-Respondents,
v.
NATIONAL LABOR RELATIONS BOARD, Respondent, Cross-Petitioner,
International Ladies Garment Workers Union, Local 89-22-1, Intervenor.

Nos. 823, 1042, Dockets 95-4100, 95-4120.

United States Court of Appeals,
Second Circuit.

Argued Jan. 3, 1996.
Decided April 2, 1996.
As Amended May 9, 1996.

Gary C. DiLeonardo, Forest Hills, N.Y. (Robert A. Schutzman, Forest Hills, NY, of counsel), for Petitioners-Cross-Respondents.

Vincent J. Falvo, Jr., National Labor Relations Board, Washington, DC (Peter Winkler, Supervisory Attorney, Frederick L. Feinstein, General Counsel, Linda Sher, Associate General Counsel, Aileen A. Armstrong, Deputy Associate General Counsel, National Labor Relations Board, Washington, DC, of counsel), for Respondent-Cross-Petitioner.

Louie Nikolaidis, Lewis, Greenwald, Clifton & Lewis, P.C., New York City (Everett E. Lewis, Greenwald, Clifton & Lewis, P.C., New York City, of counsel), for Intervenor.

Before: McLAUGHLIN, JACOBS, and CALABRESI, Circuit Judges.

PER CURIAM:

[*~743]1

Lihli Fashions Corporation, Inc., King Kuo International Enterprises, Inc., Liyan International, Inc., and Lihli, Inc. are manufacturers and marketers of upscale women's clothing. Collectively, they appeal from a decision of the National Labor Relations Board, finding that Lihli, Inc. and Liyan International, Inc.: (1) constitute a "single employer;" (2) are "alter egos" of Lihli Fashions Corporation, Inc. and King Kuo International Enterprises, Inc.; and (3) as such, are bound by the collective bargaining agreement between Lihli Fashions Corporation, Inc., King Kuo International Enterprises, Inc., and the International Ladies Garment Workers Union, Local 89-22-1.

BACKGROUND

2

Lihli Fashions Corp., Inc. and King Kuo International Enterprises, Inc. (together "LFC/King Kuo") manufactured expensive women's clothing under an exclusive contract with the famous designer, Adolfo. Adolfo marketed and sold his clothing line to upscale department and specialty stores.

3

LFC/King Kuo were owned and managed by Lihli Hsu, who was the president and chief operating officer of both entities. At various times, Lihli Hsu's children (Henry, Karen, and Ruth Hsu) worked at the LFC/King Kuo factory, located in Long Island City and owned by the Hsus.

4

The production, maintenance, and shipping workers of LFC/King Kuo were represented by the International Ladies Garment Workers Union, Local 89-22-1 ("Local 89-22-1") under a collective bargaining agreement (the "agreement"). Among other things, the agreement required LFC/King Kuo to: (a) make contributions to jointly administered pension and welfare funds; (b) grant certain wage and cost-of-living increases to employees; and (c) grant union representatives access to its premises.

5

LFC/King Kuo thereafter failed to grant its employees a cost-of-living increase due under the agreement, and ceased making required contributions to the union's pension and welfare funds. Local 89-22-1 filed grievances against LFC/King Kuo, and obtained an award after arbitration.

6

In early 1993, Adolfo announced his retirement. The last Adolfo garments were shipped, and LFC/King Kuo ceased operations. Lihli Hsu then began designing her own line of women's clothing--under the name "Lihli"--which was similar to but less expensive than the Adolfo line. The Hsu family formed two corporations to manufacture and market the Lihli line: Liyan International, Inc. ("Liyan"), which manufactures the clothes, and Lihli, Inc., which sells and markets them.

[*~744]7

Liyan is owned in equal shares by Henry and Ruth Hsu, and Lihli Hsu serves as its president. Liyan operates out of the same factory, uses most of the same equipment, retains the same suppliers, and employs many of the same workers as did LFC/King Kuo. Lihli, Inc. is owned in equal shares by Lihli, Ruth, Karen, and Henry Hsu, and Lihli Hsu serves as its president. The company operates out of Adolfo's former showroom in Manhattan, and sells most of its new clothing line to former Adolfo customers.

8

In April 1993, Lihli Hsu wrote to Local 89-22-1, stating that LFC/King Kuo "will be going out of ... business. Please note that all agreements will be terminated." Lihli, Inc. and Liyan denied Local 89-22-1 access to their employees, asserting that they were no longer a union shop.

9

Local 89-22-1 filed an unfair labor practice charge with the National Labor Relations Board ("NLRB"), alleging that LFC/King Kuo violated § 8(a)(1), (5) of the National Labor Relations Act ("NLRA"), 29 U.S.C. § 158(a)(1), (5). Specifically, the union charged that LFC/King Kuo had established alter ego corporations in order to evade their obligations under the agreement.

10

A hearing was held before Administrative Law Judge ("ALJ") Raymond P. Green. ALJ Green issued a Recommended Order, finding that Lihli, Inc. and Liyan: (1) constitute a "single employer;" (2) are "alter egos" of LFC/King Kuo; and (3) as such, are bound by the collective bargaining agreement between LFC/King Kuo and Local 89-22-1. The NLRB fully adopted ALJ Green's Recommended Order. See Lihli Fashions Corp., 317 N.L.R.B 163, 1995 WL 255650 (N.L.R.B. Apr.28, 1995).

11

LFC/King Kuo, Liyan, and Lihli, Inc. now appeal. We affirm in part and reverse in part.

DISCUSSION

[*~745]12

LFC/King Kuo, Liyan, and Lihli, Inc. seek to vacate the NLRB's decision and order, arguing that: (1) Lihli, Inc. and Liyan are not a "single employer;" and (2) Lihli, Inc. is not the "alter ego" of LFC/King Kuo. (Petitioners concede that Liyan is the alter ego of LFC/King Kuo.) Local 89-22-1 intervenes, arguing for enforcement of the NLRB's decision.

13

The determinations of both single employer and alter ego status are questions of fact. Goodman Piping Prods., Inc. v. NLRB, 741 F.2d 10, 11 (2d Cir.1984) (per curiam); NLRB v. Al Bryant, Inc., 711 F.2d 543, 551 (3d Cir.1983), cert. denied, 464 U.S. 1039, 104 S.Ct. 699, 79 L.Ed.2d 165 (1984); Limbach Co. v. Sheet Metal Workers Int'l Ass'n, 949 F.2d 1241, 1258-59 (3d Cir.1991). Factual determinations of the NLRB may be set aside only if those determinations are not "supported by substantial evidence on the record considered as a whole." 29 U.S.C. § 160(f); see also Universal Camera Corp. v. NLRB, 340 U.S. 474, 487-88, 71 S.Ct. 456, 463-65, 95 L.Ed. 456 (1951); Al Bryant, 711 F.2d at 551. Deference is given to the NLRB's decision, and all reasonable inferences are drawn in its favor. NLRB v. James Thompson & Co., 208 F.2d 743, 746 (2d Cir.1953).

I. Single Employer Doctrine

14

LFC/King Kuo, Liyan, and Lihli, Inc. argue that Liyan and Lihli, Inc. are not a "single employer." We disagree.

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Separate companies are considered a "single employer" if they are " 'part of a single integrated enterprise.' " Clinton's Ditch Coop. Co. v. NLRB, 778 F.2d 132, 137 (2d Cir.1985) (quoting NLRB v. Browning-Ferris Indus., Inc., 691 F.2d 1117, 1122 (3d Cir.1982)), cert. denied, 479 U.S. 814, 107 S.Ct. 67, 93 L.Ed.2d 25 (1986). The Supreme Court, in Radio & Television Broadcast Technicians Local Union 1264 v. Broadcast Service of Mobile, Inc., 380 U.S. 255, 256, 85 S.Ct. 876, 877, 13 L.Ed.2d 789 (1965) (per curiam), established a four-factor test to determine "single employer" status. The test examines the "interrelation of operations, common management, centralized control of labor relations and common ownership." Id. Also relevant are the use of common office facilities and equipment and family connections between or among the various enterprises. See Three Sisters Sportswear Co., 312 N.L.R.B. 853, 1993 WL 398465, at * 15 (N.L.R.B. Sept. 30, 1993); Goodman Investment Co., 292 N.L.R.B. 340, 1989 WL 223774 at * 10-11 (N.L.R.B. Jan. 17, 1989). To demonstrate single employer status, not every factor need be present, and no particular factor is controlling. See Three Sisters, 1993 WL 398465, at * 15. "Ultimately, single employer status depends on all the circumstances of the case and is characterized by absence of an 'arm's length relationship found among unintegrated companies.' " Al Bryant, 711 F.2d at 551 (citation omitted).

16

Here, the NLRB concluded that Liyan and Lihli, Inc. are a "single employer," and there is substantial evidence to support this finding. The operations of Lihli, Inc. and Liyan are functionally integrated. The garments manufactured by Liyan are exclusively sold to and marketed by Lihli, Inc.; Lihli, Inc., in turn, provides services solely to Liyan. Lihli, Inc. and Liyan also have overlapping ownership and control: Liyan is owned in equal shares by Henry and Ruth Hsu; and Lihli, Inc. is owned in equal shares by Lihli, Ruth, Karen, and Henry Hsu. See, e.g., Goodman Piping, 741 F.2d at 11 (common ownership and control established through familial relationships). Lihli Hsu serves as president of both companies, splits her time between the Manhattan showroom and the Long Island factory, and exercises ultimate business and artistic control over both entities. All members of the Hsu family receive payroll checks from both corporations. There is also evidence of centralized control of labor relations--both companies share some employees and appear to make joint hiring and firing decisions.

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But, critically, the determination that separate companies are a "single employer" is not enough to bind all the separate companies to the collective bargaining agreements of any one of the companies. Rather, something more must be shown. As the Supreme Court held in South Prairie Construction Co. v. Local No. 627, 425 U.S. 800, 96 S.Ct. 1842, 48 L.Ed.2d 382 (1976) (per curiam), for one company to be bound by a collective bargaining agreement made by another company, it must be shown not only that they are a "single employer," but, additionally, that together they represent an appropriate employee bargaining unit. Id. at 804-05, 96 S.Ct. at 1844-45; see also Truck Drivers Local Union No. 807 v. Regional Import & Export Trucking Co., 944 F.2d 1037, 1046 (2d Cir.1991) (holding that "single employer/single unit doctrine" has "the same binding effect on a non-signatory" as the "alter ego doctrine"); Local One v. Stearns & Beale, Inc., 812 F.2d 763, 769 (2d Cir.1987) ("[T]o bind a non-signatory company to a collective bargaining agreement, both single employer and single bargaining unit status must be found."); Stardyne, Inc. v. NLRB, 41 F.3d 141, 144 (3d Cir.1994) ("When two entities are found to be a single employer, one entity's collective bargaining agreement covers the other entity as well, provided that the two entities' employees constitute a single appropriate bargaining unit.").

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Thus, even though Lihli, Inc. is a "single employer" with Liyan, and Liyan is concededly bound by the collective bargaining agreement between LFC/King Kuo and Local 89-22-1, Lihli, Inc. is not bound by that agreement unless it and Liyan constitute an appropriate bargaining unit. The parties concede that the sales and marketing employees of Lihli, Inc. do not constitute an appropriate bargaining unit with the production, maintenance, packing, and shipping employees of Liyan. Thus, while Liyan is bound by the collective bargaining agreement between LFC/King Kuo and Local 89-22-1, Lihli, Inc. is not so bound. See South Prairie, 425 U.S. at 805-06, 96 S.Ct. at 1844-45.

19

We note, however, that the mere status of Liyan and Lihli, Inc. as a "single employer" has independent legal significance. Specifically, that finding is enough to hold them jointly and severally liable for each other's debts and obligations, including financial obligations under the collective bargaining agreement. See Cook v. Arrowsmith Shelburne, Inc., 69 F.3d 1235, 1240 (2d Cir.1995) (in Title VII context, parent-subsidiary liability established by showing of "single employer" under four-part test); NLRB v. International Measurement and Control Co., 978 F.2d 334, 340 (7th Cir.1992) (parent corporation liable for obligations to employees under collective bargaining agreement between subsidiary and union).

II. Alter Ego Doctrine

20

Although conceding that Liyan is the "alter ego" of LFC/King Kuo, petitioners contend that Lihli, Inc. does not hold the same status. We agree, and reverse the NLRB's decision in that regard.

21

The "hallmarks of the alter ego doctrine include 'whether the two enterprises have substantially identical management, business purpose, operation, equipment, customers, supervision, and ownership.' " Truck Drivers, 944 F.2d at 1046 (quoting Goodman Piping, 741 F.2d at 11). If two companies are deemed alter egos of each other, then each is bound by the collective bargaining agreements signed by the other. See Howard Johnson Co. v. Detroit Local Joint Executive Bd., 417 U.S. 249, 259 n. 5, 94 S.Ct. 2236, 2242 n. 5, 41 L.Ed.2d 46 (1974); Southport Petroleum Co. v. NLRB, 315 U.S. 100, 106, 62 S.Ct. 452, 455-56, 86 L.Ed. 718 (1942); Truck Drivers, 944 F.2d at 1046.

22

While the alter ego doctrine has "the same binding effect on a non-signatory as the single employer/single unit doctrine," the two doctrines are "conceptually distinct." Truck Drivers, 944 F.2d at 1046. The focus of the alter ego doctrine, unlike that of the single employer doctrine, is on " 'the existence of a disguised continuance or an attempt to avoid the obligations of a collective bargaining agreement through a sham transaction or technical change in operations.' " Id. (quoting Carpenters Local Union No. 1846 v. Pratt-Farnsworth, Inc., 690 F.2d 489, 508 (5th Cir.1982), cert. denied, 464 U.S. 932, 104 S.Ct. 335, 78 L.Ed.2d 305 (1983)); see also Goodman Piping, 741 F.2d at 12 (evidence of "anti-union animus or an intent to evade union obligations ... may be 'germane' ") (citation omitted). Thus, the alter ego test is notably different than the "four-factor" single employer test, as other courts have recognized. See, e.g., Stardyne, 41 F.3d at 152; Local 701 v. Favia Elec. Co., 995 F.2d 785, 788-89 (7th Cir.1993).

23

While Liyan is concededly the alter ego of LFC/King Kuo, Lihli, Inc. cannot be so characterized. True, they all share common ownership and management, but the record indicates that Lihli, Inc. has a business purpose completely different from Liyan and LFC/King Kuo. Lihli, Inc. was formed to fill the gap created by Adolfo's retirement. Prior to his retirement, Adolfo exclusively marketed and sold his clothing line, a function never performed by either LFC/King Kuo or Liyan. Adolfo's company was a separate and distinct entity, and it was not bound by the collective bargaining agreement between LFC/King Kuo and Local 89-22-1. Moreover, although Lihli, Inc. took over Adolfo's Manhattan showroom and sells to many former Adolfo customers, Lihli, Inc. uses none of the same equipment as, nor does it have customers in common with, Liyan or LFC/King Kuo.

24

In addition, while the decision to dissolve LFC/King Kuo and form Liyan was clearly "an attempt to avoid the obligations of [the] collective bargaining agreement," Truck Drivers, 944 F.2d at 1046, there is no evidence indicating that the formation of Lihli, Inc. was motivated by the same intent. Rather, as noted above, Lihli, Inc. stepped into the fashionable shoes previously worn by Adolfo. Nothing in the record is inconsistent with the conclusion that Lihli, Inc. was established in a legitimate attempt to market and sell products that had previously been marketed and sold by another company.

CONCLUSION

25

In summary, we find that there is insubstantial evidence to support the NLRB's conclusion that Lihli, Inc. is the alter ego of LFC/King Kuo, and reverse the NLRB's decision on this issue. We find, however, that there is sufficient evidence to support the NLRB's finding that Liyan and Lihli, Inc. constitute a single employer, and thus affirm on this issue. We note, however, that while Lihli, Inc. is not bound by the collective bargaining agreement, Lihli, Inc.--as a single employer with Liyan--may nonetheless be held liable for any of Liyan's obligations under the collective bargaining agreement.

26

Accordingly, the decision of the NLRB is A FFIRMED IN PART AND REVERSED IN PART.