The union decertified, negating its existence as a collective bargaining agent, and allowing players to sue the NFL about the restraints in place.

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Last-hired, first-fired agreements are not debt, but they are contracts which cannot be cleared and depending on the strength of the collective bargaining agent, have a high cost of breach.

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With the NFL allowed to impose its restraints through an impasse in bargaining and seemingly free to impose their system on the players as long as the players had a collective bargaining agent (union), Upshaw decided to have the players become antitrust litigants rather than union members.

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Over the telephone, his bargaining partner, a corporate agent, told him he was putting too much emphasis on the clause we wanted.

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Manning, not previously involved in any bargaining, is scheduled to become a free agent, pending the negotiation of the Franchise tag application between the two sides.

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That's probably why he's playing serious hardball during the current tense round of negotiations over the league's collective-bargaining agreement, the result being a 72-hour postponement of the free-agent shopping season that was to have begun on Monday.

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