Can a AC21 letter substitute for I-140 withdrawal?

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Registered Users (C)
Folks,

I know that in a case, when an approved I-140 is revoked by sponsoring employer, the AC21 letter from the new employer can substitute it.

However, I need to know if the same AC21 letter can substitute a pending I140 that is withdrawn by the sponsoring employer.

Bottomline, can a AC21 letter filed for I-485 pending well over 180+ days form a basis for the final GC approval?

Thanks.
 
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