AC21 Portability after TUB

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Hello Friends,

My 485 was filed in Oct 2020 with EB3 downgrade and later I interfiled upgraded to EB2 thru TUB in June 2022 and my case remains pending in FO as the PD retrogressed. Do I have to wait 180 days from June 2022 (the date of interfiling) to be able to utilize AC21 portability? Also, should I now consider that my 485 is already in EB2 Queue ? Appreciate your help. Thank you!

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