The National Labor Relations Board announced on March 12, 2013, that it will not seek en banc rehearing of Noel Canning v. NLRB et al., Nos. 12-1115 and 12-1153 (D.C. Cir. Jan. 25, 2013), in which the U.S. Court of Appeals for the District of Columbia Circuit held that the President’s January 4, 2012 recess