Part of the problem of organizing the players was confusion about the type of association they were forming. The NHLPA had applied, in Canada, to the Ontario Labour Relations Board for certification, but the ORLB had no experience with workers like hockey players. NHLPA members negotiated individual contracts and wanted to continue to bargain this way. The matter of the NHLPA being an actual union, where the members were bound together and fought for collective agreements, was unclear. The NHLPA legal counsel, Milton Mound, addressed this, saying that the players would negotiate on matters common to all players (pensions, allowances) but retained the right to individual contracts. The League, and especially Conn Smythe, argued that players were forming a "trade union" and were no better than "commies" and would lose things like individual bonuses. He believed that hockey players were in the business of being "independent contractors" and had no right or reason for a collective organization.