How would you analyze in IRAC form the following?

Vargas Enterprises v. National Labor Relations Board

The National Labor Relations Act of 1935 (NLRA) prohibits employers engaged in interstate commerce from interfering with the right of their workers to form a union. Vargas Enterprises is a small manufacturing firm with facilities in Yuma and Bisbee, Arizona. Sales of the clothing it manufactures generate $25 million per year in revenue, approximately 30% of which comes from out of state sales. Finding that Vargas unlawfully interfered with the union organizing activities of its machine operators in both Yuma and Bisbee, the National Labor Relations Board imposed a substantial fine for violating the NLRA. Vargas countered by challenging Congress's constitutional authority to regulate its manufacturing operations under the Commerce Clause. Under Gibbons, will Vargas's constitutional challenge prevail?