 Takahashi was an employee at Dentsu, Japan's leading advertising agency, and worked more than 100 hours' in the months prior to her death—her death was ruled as "karōshi".Under the Japanese Constitution article 28 everyone has the right to unionise and to collectively bargain.Under the Trade Union Act of 1949 article 7(2) an employer's refusal to bargain with a union in good faith, without a good reason, is an unfair labour practice.