This is the footnoted version of our Blogpost by the same title. It gives more detail and refers to other articles that are available on our website. This is an area of obvious interest to me, to many of our clients, and to you also, if you are reading this. The law regarding § 203(h) is still in a state of "discovery." The courts have decided that the statute means what it says. It is now up to the appropriate agencies to decide the proper approach or approaches. The two-petition solution will definitely work in the Fifth and Ninth Judicial Circuits. I propose a single-petition solution supported by existing laws and regulations and which offers the advantages of speed, economy, and simplicity.