Assuming Cournot competition, Bughin (1999, The strategic choice of union-oligopoly bargaining agenda', International Journal of Industrial Organization) states that in a unionized oligopoly with firm specific negotiations, Efficient Bargaining (EB) is always the industry equilibrium both under blockaded and non-blockaded market structures. Extending Bughin's (1999) framework to a conjectural variation model, this note shows that EB emerges as equilibrium only for entry deterrence reasons. In all other cases, conflict of interests among the bargaining parties arise due todifference in dominant strategies, whatever is the degree of competitiveness of the industry. (C) 2011 Elsevier B.V. All rights reserved.