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I have read the text of the memo in its entirety. Unfortunately, this memo does not address some of the key issues of the 180-day rule.
(1) The memo does not say whether the rule will be applied retroactively.
(2) The memo avoids the question "what if the original sponsoring employer withdraws the certification or Form I-140."
(3) The memo states that "the Service is currently formulating proposed regulations to establish a policy framework in which to adjudicate AC21 $106(c) benefits." In other words, we shall wait for the final regulations.
The law itself is so vague that you can really interpret it in either way. I guess it\'s too early to celebrate. There is little new information regarding AC21 $106(c) except that we know that our I-485 will not be denied on the basis that we have changed our job after 180 days. However, whether the application will be approved is another question.
Nevertheless, the memo does address many other important issues related to H1-B. Also, it looks that the regulation is favorable towards those who jumpped ship relying upon the 180-day rule.
Of course, I am eager to see the professional analyses from major immigration portals.