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The UAW brief notes that UAW women members are, in general, paid more than most women simply because they belong to a union, but pay equity issues remain. The union argues that pay equity can be successfully negotiated at the bargaining table, provided a separate fund is set up to prevent employers from shifting compensation dollars to female-dominated jobs from male jobs. It notes sex segregation contributes significantly to the wage gap in factories and, since employers use “merit” to avoid paying women fairly, it should not be allowed as an exception under pay equity laws.