EB-1C Filing after 3 year term in US for the same company


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I have worked for the company A outside USA for 1+ years in managerial capacity. Company A transferred me to USA in Nov'2015. I have been in managerial capacity in the same company A till now.  My question is - Will my company be able to file an EB-1C I-140 after the three year. 

https://www.murthy.com/2018/05/10/aao-on-one-in-three-rule-for-eb1c-multinational-managers-executives/ 

As per the rule (above link) / update on the one in three rule, the only requirement is not to switch companies in between.  Also if I understand it correctly, I believe the I-140 application can be filled after three years. The three year considered here is the three year prior to admission in to USA. 

In my case, I entered in Nov'2015. Though it is already Nov'2018, I believe the company can still file the I-140 on EB-1C. 

Can some one please answer or confirm if my understanding/analysis is correct. 

 

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