Circuit Split Over Thryv Remedies. On October 20, 2025, the U.S. Court of Appeals for the Ninth Circuit generally upheld expanded make-whole remedies contemplated by the National Labor Relations Board (the “Board”) in Thryv, Inc., 372 NLRB No. 22 (2022). But since Halloween this year, both the Fifth and the Sixth Circuits joined the Third Circuit in rejecting Thryv remedies.… Continue Reading