REINHARDT, Circuit Judge:
The primary question before us is what a union must do to comply with the provision of section 401(e) of the Labor-Management Reporting and Disclosure Act of 1959 ("LMRDA") that requires unions to give notice of union elections to their members. Here we consider the rules that apply when notice is given by mailing the union newspaper to the membership. There is little case law on point.
I. Facts and Proceedings
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