RFE on tenure in USA


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I have applied for COS fro L1 to H1.USCIS has raised an RFE saying that I have expired my time period in USA and cannot give approval for 3years.

Here is my history

Entry into USA March 2006 L1B

3 weeks vacation in June 2009

Exit from USA Sep 2009

Entry into USA March 2011 (New L1b)

Was not in USA for 18 months

But USCIS says I have been in USA since 2006.

I have always submitted my I94s.

My employer is going to submitt all pages of my passport copy.Is this good enough or is there something else to be provided? Help from firm is highly appreciated.

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