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H1B RFE Maintenance of status (multiple years of practical training)

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I have a RFE for my F1 to H1B petition saying I have 'multiple years of practical training while on same education level'. It says I have 15 months of practical training as an undergraduate.

In reality, I have roughly 14 months of CPT in total but only 11 months were FULL TIME CPT. The rest was part time CPT. I was under the impression that part-time CPT had no bearing on the 365 day limit for CPTs (to be considered for OPT and furthermore H1Bs). Any advice on how to approach this would be much appreciated. Thanks!

Edited by Aguptaa

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consult an attorney... You are in trouble.  If you are more than 12 months on any practical training (full time or part time) on same education level, then you are not eligible for OPT.

Edited by satya2k1

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