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1 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 1 of 11 Brent W. Renison, OSB No. 96475 E-mail: [email protected] Parrilli Renison LLC 610 SW Broadway Suite 505 Portland, OR 97205 Tel: (503) 597-7190 Attorneys for Plaintiffs UNITED STATES DISTRICT COURT DISTRICT OF OREGON PORTLAND DIVISION TENREC, INC., SERGII SINIENOK, Case No. 3:16-cv-00995-SI WALKER MACY LLC, XIAOYANG and all others similarly situated, ZHU, PLAINTIFFS' REPLY TO Plaintiffs, DEFENDANTS’ RESPONSE TO PLAINTIFFS’ MOTION FOR v. SUMMARY JUDGMENT U.S. CITIZENSHIP AND IMMIGRATION SERVICES, and LEON RODRIGUEZ, ship and Immigration Director, U.S. Citizen Services, Defendants. Plaintiffs, by and through Brent W . Renison, undersigned counse l, hereby reply to (ECF No. 34), filed by all Defendants’ Response to Plaintiffs ’ Motion for Summary Judgment fully request the Court grant Pl defendants. Plaintiffs respect aintiffs’ Motion for Summary Judgment (ECF No. 31). In response to plaintiffs’ disc ussion about the inequity create d by multiple filings for the same beneficiary, defendants ch aracterize this discussion as me rely “policy complaints that ignore how Section 1184(g)(3) is s ilent regarding both (1) what the agency must do with ’s fiscal cap has been reache d and (2) how to process a sudden petitions received after each year RESPONSE TO PLAINTIFFS’ MOTION FOR PLAINTIFFS’ REPLY TO DEFENDANTS’ SUMMARY JUDGMENT – Page 1

2 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 2 of 11 petitions received all at on ce.” Def. Response, p. 4 (ECF No. influx of hundreds of thousands of 34). Plaintiffs, however, do not i gnore the language of § 1184 (g)(3) as that language relates to what the agency must do with pet itions received after a fiscal cap has been reached. Instead, plaintiffs have consistently ar gued that defendants must contin ue to accept petitions all year and assign them a priority date orde r of filing, which date must th en later be used to distribute H-1B he earlier petition filing date. visas or status according to t The language of § 1184(g)(3) plainly states that numerically restric to given visas or status in petition ted “aliens” (not petitions) are filing date order, and § 1184(c)(1) governing the filing of H-1 B “petitions” (not aliens) contains no such numerical limit. If Congr ess had intended to limit pet ition filings, it would have inserted the numerical limit in § 1184(c)(1 ) (dealing with petitions) an d not § 1184(g)(1) (dealing with aliens). This is not silence, as defendants’ characterization suggests, but plain language sas or status to aliens based on the providing unlimited petition fili ng, but limited issuance of vi filed. Defendants suggest that order in which the petition was § 1184(c)(1), which states that the question of importing a nonimmig all be determined...upon rant under § 1101(a)(15)(H) “sh petition of the importing employe r” and that “[s]uch petition s hall be made and approved before the visa is granted” is silent w ith respect to what the agency must do with “such petition.” Because the statute directs an importing employer to make a pet ition before a visa may be granted, and does not limit whe n a petition must be filed other than before a visa is granted, this approval of such a petition shall not, is not silence. Additionally, § 1184(c)(1) states that “[t]he lishing that the alien is a non of itself, be construed as estab immigrant” which shows that a petition is a precursor to visa nsidered an H-1B nonimmigrant, the eligibility. In order to be co statutory scheme still requires the availability of an H-1B vis a number or status adjustment under the limits imposed by § 1184(g)(1 ) and in order of petition fil ing date as directed by § 1184(g)(3), as well as any necessary Labor Condition Applicat ion required prior to admission under § 1182(n). The statutory sch eme is not silent with respe ct to what the agency must do with on as a prerequisite to an alien being a petition, since it must accept such petition without limitati PLAINTIFFS’ REPLY TO DEFENDANTS’ FOR RESPONSE TO PLAINTIFFS’ MOTION SUMMARY JUDGMENT – Page 2

3 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 3 of 11 rant. eligible for consideration for a quota limited visa or status g Defendants seek to leverage the absence of a wait list provisio n in § 1184(g) into an ambiguity over the order of cons ideration for limited H-1B visa s or status in spite of specific language in § 1184(g)(3) which matches language in § 1153(e)(1) . But the Supreme Court has foreclosed this type of isolationist approach: “A statutory ‘provision that ma y seem ambiguous in isolation is often clarified by the remainder of the statutory scheme...because only one of the p ermissible ffect that is compatible with meanings produces a substantive e the rest of the law.’ rs of Inwood Forest Associates, Ltd ., 484 United Sav. Assn. of Tex. V. Timbe U.S. 365, 371, 108 S.Ct. 626, 98 L.Ed.2d 740 (1988). Thus, an a gency interpretation that is ‘inconsisten[t] w ith the design and stru cture of the statute as a whole,’ University of Tex. Southweste rn Medical Center v. Nassar , 570 U.S. __, __, 133 S.Ct. 2517, 2529, 1867 L.Ed.2d 503 (2013), does not mer it deference.” , 134 S.Ct. 2427, 2442 (2014). The remainder of the Utility Air Regulatory Group v. EPA (1), clarifies that when C ongress utilizes language “in the statutory scheme, including § 1153(e) order in which a petition is filed” for distributing fiscal yea r numerically limited visas or status to ribution is to be in order of p t petitions are to aliens, that this means the dist etition filing, and tha be filed without arbitr ary limitation. The agency interpretati on which includes distribution onsisten[t] with the design and structure of the statute as a through random lottery, is “inc .” Utility Air Reg. Group, supra , quoting Univ. of Tex. Southwestern Medical Center v. whole Nassar, supra . Thus, according to recent Suprem e Court precedent, the agenc y interpretation does not merit deference. With respect to defendants’ claim out “how to process a sudden that the statute is silent ab influx of hundreds of thousands of petitions received all at on ce,” Def. Response, p. 4 (ECF No. 34), the answer is that this s ituation is entirely created by d efendants’ refusal to accept petitions all year in accordance with the statutory scheme intended by Co ngress. If petitions were accepted all year, instead of i n 2 or 5 days per year (which is a patently arbitr ary timeframe), employers would file them all year-round, resulting in a gradua l flow of petitions in date filing e who filed earlier would have order, instead of a flood. Thos an earlier priority date and an PLAINTIFFS’ REPLY TO DEFENDANTS’ RESPONSE TO PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT – Page 3

4 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 4 of 11 earlier consideration for an H-1B s precisely what Congress intended visa or status grant. That i ited visa numbers would be given when it specified that the lim out in petition filing date order, creating an orderly sy stem of distribution. The lottery system that defendants now defend is far it depends on chance and totally from orderly, or fair, because disregards petition filing date order. Defendants in their Res ponse completely sidestep the ar bitrary nature of the lottery process for distribution of quota limited visas or status. Defendants seek to analogize thei r claim of statutory silence r egarding rejection of petitions and running of a lotter ip-pooling issue presented in y selection process with the t Oregon Restaurant & Lodging Association v. Perez , 816 F.3d 1080 (9th Cir. 2016), reh’g en banc denied , __ F.3d __, 2016 WL 4608148 (9th Cir . Sept. 6, 2016). While the reasoning of the Court in Perez is unquestionably correct, plaint iffs reject de fendants’ chara cterization of the case ilence as to employers , the statute’s “clear s as one similar to the case at bar. In Perez in Perez who do not take a tip credit has le lgate the 2011 rule.” Id . at 1088. ft room for the DOL to promu There is no such silence here which would allow defendants the freedom to reject petitions and herd them into a 5 day filing wi ndow, drawing straws to determi ne which petitions to accept or reject. Plaintiffs do not argue tha t there is a statutory sile nce which “repudiates” agency action. Instead, plaintiffs consider the s tatutory scheme, viewed in it s entirety, as unambiguously winners and losers through a forbidding the rejection of petitions and the selection of H-1B computer generated random lottery process. The Supreme Court has determin ence which is more ed the meaning of a statutory sil analogous to the case at bar, in , 133 S.Ct. 2120 Tarrant Regional Water Dist. v. Hermann (2013). In Tarrant , the Court had to decide wheth er silence regarding state borde rs in § 5.05(b)(1) of the Red Riv er Compact, Act of Dec. 22, 1980, 94 Stat. 3305; Compact, 1 App. 7- 51, had significance where other se ctions of the Act had specif ic language “within their respective boundaries” and where the plaintiff claimed borders were irrelevant when interpreting The Court found that “Tarrant’s § 5.05(b)(1) because of the latter’s silence on state borders. RESPONSE TO PLAINTIFFS’ MOTION FOR PLAINTIFFS’ REPLY TO DEFENDANTS’ SUMMARY JUDGMENT – Page 4

5 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 5 of 11 te borders means borders are no t applicable] fails to account for argument [that silence about sta other sections of the Compact tha t cut against its reading” and stated that “[a]pplying Tarrant’s understanding of § 5.05(b)(1 )’s silence regard ing state lines t o other of the Compact’s provisions would produce further an omalous results.” Id . at 2131. The Court pointe d to another section of the Compact, § 6.01(b) which was also silent on the issue of st ate lines: “Consider § 6.01(b). That provisi on states that ‘Texas is appo rtioned sixty (60) ve unrestricted use percent of the runoff of [subbasin 1 of Reach III] and shall ha thereof; Arkansas is entitled t ff of this subbasin.’ o forty (40) percent of the runo Id., at 32. Because Texas is upstream from Arkansas, water flo ws from Texas to Arkansas. Given this situati on, the commonsense reason for § 6 .01(b)’s 60-to-40 allocation is to prevent Texas fr om barring the flow of water t o Arkansas. While there is no reference to state bound aries in the section’s text , the unstated assumption underlying this provisio n is that Arkansas must wait for its 40 percent share to go through Texas before it can claim it. But applying Tarrant’s n would imply that understanding of silence regardi ng state borders to this sectio without having to wait for the water that will Arkansas could enter into Texas inevitably reach it. This count erintuitive outcome would thwar t the self-evident , other provisions of the Comp act share this purposes of the Compact. Further om an upstream State structure of allocating a proportion of water that will flow fr to a downstream one. Accepting Tar rant’s reading would upset t he balance struck by all these sections. , 133 S.Ct. at 2131-32. In Tarrant , the Supreme Court found an “unstated Tarrant, supra assumption” in the statute whic h meant state boundaries applied even when the particular statutory section was silent a bout them. Here, the unstated as sumption is that because Congress order in which petitions are filed for directed the agency t o distribute H-1B visa s or status “in the such visas or status” as pl n the use of a wait list applies ainly commanded by § 1184(g)(3), the because the other statute utilizing this plain language, § 1153 (e)(1), uses a wait list and a contrary system of apportionment such as a lottery would result in a “counterintuitive outcome [that] would thwart the self-evi dent purposes” of the statute. Tarrant, supra . Congress drafted § 1184(g)(3) with the system al ready in place under § 1153(e)(1 ) in mind, and with the self- evident use of wait lists in m ind. There is no other logical w ay of distributing limited visas st. The agency cannot make aliens based on a petition filing date other than through a waiting li FOR PLAINTIFFS’ REPLY TO DEFENDANTS’ RESPONSE TO PLAINTIFFS’ MOTION SUMMARY JUDGMENT – Page 5

6 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 6 of 11 ncy for months or years, so the wait list is the logical distribution stand in a line outside the age method. Taking § 1184(g)(3)’s silen ce with regard to wait list s to mean that the agency can reject petitions almost year-r ound and force employers to file in a 5 day window, conducting a random lottery by computer to dist ribute visas in arbitrary fas hion is folly. Defendants also argue that thei r interpretation of the statute is reasonable because g waiting list for H-1B petitions to adopting plaintiffs’ interpretati on would “create a never-endin e and employment-related h years-old labor, prevailing wag be adjudicated (oftentimes wit information).” Def. Respons e, p. 8, ECF No. 34. Merely claimi ng that plaintiffs’ interpretation asonableness of defendants’ own is not reasonable, howev er, is not the same as defending the re interpretation. First, such a waiting list is not never ending , because 85,000 visas or status will be distributed each year to those with the earliest filing date s. The only potentially never-ending situation is lottery non-selec tion year after year due to the i nherent arbitrarines s of the lottery. age used in the immigrant visa Second, Congress knew prior to 1990 t hat nearly identical langu context in practice resulted i ng that language in § 1184(g). Third, n a wait list long before inserti aims made by plaintiffs which tery system from specific cl defendants fail to defend their lot render the agency interpretati on unreasonable in cluding: 1) lar ger employers with multiple entities, and enterprising beneficiaries with multiple job offe rs from multiple different employers can game the system for a better c hance in the lottery (Plainti ffs’ MSJ, p. 15, ECF No. 31); 2) it is possible for an individual to have been the beneficiary of a n H-1B petition in multiple years, ains a winning lottery number in and have been rejected each time, w hile another beneficiary obt the first year (Plaintiffs ’ MSJ, p. 21, ECF No. 31); and 3) a p etitioner which files for two or three on a de facto waiting list for an ected is in effect being placed or more years without being sel de facto who file later are allowed a vi sa ahead of them (a cut in H-1B number, except that others line). (Plaintiffs’ MSJ, p. 32). D efendants in their Response chose not to direc tly address any of these concerns about the reasonabl eness of the rejection and lo ttery system. In refusing to ils. address these effects head on, t heir claim to reasonableness fa RESPONSE TO PLAINTIFFS’ MOTION FOR PLAINTIFFS’ REPLY TO DEFENDANTS’ SUMMARY JUDGMENT – Page 6

7 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 7 of 11 , defendants insist there is a “ crucial difference” between In defending the lottery system nonimmigrant and immigrant statu tes, urging the Court to disreg ard the mirror statutory language of 8 U.S.C. § 1153(e)(3 ). Def. Resp. MSJ, p. 8, ECF N o. 34. The Supreme Court has counseled, however, that “[t]he pl ainness or ambiguity of statu tory language is determined [not only] by reference to the language itself, [but as well by] the specific context in which that ntext of the statute as a w language is used, and the broader co , 135 hole.” Yates v. United States and § 1184(g) is nearly language of § 1153(e)(3) S.Ct. 1074, 1081-82 (2015). Here, the early numerical limitation on an identical, the specifi c context in which bot h are used is the y alien’s admission, whether as an immigrant or nonimmigrant, int o the United States; the specific context in which the language i s used is on the one hand immigr ant visas given to aliens, and on ader context of the statute as a the other hand non-immigrant visa s given to aliens; and the bro k to distribute limited visas or status which apply to numbers of whole is that both statutes see aliens, and not petitions, so that only that many aliens can be admitted in that particular status nt) each fiscal year. Those ar (whether immigrant or nonimmigra e the considerations that the Supreme Court requires be cons ulted, and plaintiffs respectfull y submit that whether an alien is rtance to the meaning of those admitted as an immigrant or as a nonimmigrant is of lesser impo order of consideration of nume rically limited visas to aliens in the statutory provisions than is the order in which a petition is filed. In other words, the distin ction between immigrants and nonimmigrants in the statute is not one of those contextual ind icators that causes one to view the same statutory language compl e to convince the Court that this etely differently. Defendants hop distinction is key to the interpr etation of the statute, becaus e their own policy concerns about nonimmigrant petitions becoming “stale” supports their unreason able interpretation. But this distinction is a false distinct ion. The statutes are nearly id entical with respect t o the distribution of fiscal year limitations on a liens of both types, and the ent ire statutory scheme forbids the lottery system to distribute one t ype while the other type is d istributed in filing date order. Moreover, defendants focus on the final status that each nonimm igrant and immigrant FOR PLAINTIFFS’ REPLY TO DEFENDANTS’ RESPONSE TO PLAINTIFFS’ MOTION SUMMARY JUDGMENT – Page 7

8 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 8 of 11 hile ignoring the reality that an immigrant petition may just as achieve at the end of the day, w easily become “moot” if the pe titioning employer no longer wish es the services of the beneficiary being sponsored for a green card due to a long wait and passage of time. Likewise, for family based immigrants, fam ily disagreements or loss of af fection can often lead a petitioner l years. There is no indication in ng waited on a list for severa to withdraw a petition after havi the statute, nor in legislative ss meant to treat immigrants and history, to suggest that Congre nonimmigrants differently in the way that fiscal year numerical limitations on aliens were administered, just because one i s temporally limited to 6 years (albeit with unlimited 1 and 3 year extensions possible in certa in circumstances) and the othe r is not. Each category must have a petition filed, and each alien is limited per fiscal year, le ading to the conclusion that Congress envisioned each kind of alien w period of time before being ould end up having to wait for a eded the number of slots available given a visa or being admitted if the number of applicants exce for such aliens in a given fiscal year. Defendants argue that just because Congress has mandated a rand om process of distribution in the Divers ity Visa Lottery, 8 U.S.C. § 1153(e)( 2), that does not mean it is precluded from instituting a lottery to distribute numbers in a nother context. While such a generalized statement has some truth in the abstract, defendant s’ argument as applied to this statutory scheme might have gr eater force if § 1184(g)(3) did n ot contain specific language as to how limited H-1B visas and statu s were to be distributed. The specific language of § 1184(g)(3) pretation precludes such an interpretati expressio unius est on. The canon of statutory inter ess acted intentionally when it included , creates a presumption that Congr exclusion alterius particular lottery language i n one section but omitted it in an other section of the same Act. Russello v. United States , 464 U.S. 16, 23, 104 S.Ct. 296, 78 L.Ed.2d 17 (1983). Not on ly was it omitted, but contrary language was explicitly inserted. The th ree statutory sections, 8 U.S.C. § 1153(e)(1), § 1153(e)(2), and § 1184(g )(3) were all sections of the same Act, the 1990 presumption that this “disparate Immigration Act. Defendants have not sufficiently rebutted the FOR RESPONSE TO PLAINTIFFS’ MOTION PLAINTIFFS’ REPLY TO DEFENDANTS’ SUMMARY JUDGMENT – Page 8

9 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 9 of 11 tional as is required by that canon of statutory interpretation. inclusion or exclusion” was inten Russello , Id . at 23. Here, there exists not only a disparate inclusion (in cluding petition filing date order in two sections, and ra ndom order in one section), but al so a disparate exclusion (excluding random order in two sections, wh ile excluding filing date order in one section). That is more he overall statutory scheme, than mere silence. In reviewing t the Court may presume that ctly in a random order” for mandated distribution in “stri Congress acted purposely when it Diversity Visa applicants, and m andated distribution according to petition filing date order for preference immigrants and H-1B nonimmigrants. With respect to defendants’ disc ussion of the U visa program (D ef. Resp. at 12-14), and the priority date and wait list system employed there, plaintif fs admit that the U visa statute does not mandate a particular order or system of apportionment of fi scal year numerically limited ific statutory mandate, defendants visas. Plaintiffs also concede th at in the absence of any spec may have acted within their statutory authority to fill a gap c n distribution of reated by Congress i at the creation of a petition filing . Plaintiffs have not argued th the numerically limited U visas date system and wait list for the U visa program requires that the agency also institute such a ead, plaintiffs point to defendants ’ use of this apportionment system system for H-1B visas. Inst as an indication that the agency has been able to successfully distribute numerically limited nonimmigrant visas (in addition t o immigrant visas already disc ussed elsewhere) in an orderly , including § 1184(g)(3), not the U fashion through use of this system . It is the statutory scheme distribution of H-1B visas or s visa regulations, which require iling date order. tatus in a petition f Indeed, defendants’ attempt to dr tween immigrant and aw a meaningful distinction be nonimmigrant categories as relat es to fiscal year numerical lim itations loses force when viewed in light of the U visa program distribution system. Just as on e might say that an employer’s need for a highly skilled employee may diminish over a long period o f time if the H-1B visa does not become available for use, a pros ecutor’s need for a U visa witn ess may also diminish over time ority date and wait list program on its as the statute of limitations c loses in. The agency uses a pri PLAINTIFFS’ REPLY TO DEFENDANTS’ RESPONSE TO PLAINTIFFS’ MOTION FOR SUMMARY JUDGMENT – Page 9

10 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 10 of 11 own initiative even in the face of this diminishing need. The agency has adopted a mechanism to give those who are on the waitlis t a temporary authorized statu s for U visa petition beneficiaries, and it is possible that similar treatment may be provided to H- 1B petition beneficiaries who are nt in the Science, Technology, ent regulations an F-1 stude on a waitlist. In fact, under curr Engineering and Math (“STEM”) di sciplines can obtain a 24-month extension of Optional uthorization bey Practical Training (OPT) work a ond the initial 12 months of OPT, for a total of 3 years of OPT, which can enable a STEM beneficiary significantly better chances of weathering a tus. The administration has exte nded the OPT program in the past, several-year wait for H-1B sta including to fill the gap between expiration of F-1 status and the start of H-1B status (called “cap-gap”) and could do so in the future for those on a wait li st. Most importantly, however, is iority date and wait list syst em shows that the agency has adopted that utilization of the U visa pr it with success in another nonimm ed numerically. This undermines igrant category which is limit the defendants’ arguments that a wait list system would prove u nworkable for H-1B visas. For the reasons given above, a nd based upon the written submiss ions of the parties, plaintiffs respectfully request mary Judgment (ECF No. 31) be that Plaintiffs’ Motion for Sum granted. PARRILLI RENISON LLC By /s/ Brent W. Renison BRENT W. RENISON PARRILLI RENISON LLC 610 SW Broadway Suite 505 Portland, OR 97205 Phone: (503) 597-7190 [email protected] OSB No. 96475 FOR RESPONSE TO PLAINTIFFS’ MOTION PLAINTIFFS’ REPLY TO DEFENDANTS’ SUMMARY JUDGMENT – Page 10

11 Case 3:16-cv-00995-SI Document 35 Filed 11/16/16 Page 11 of 11 CERTIFICATE OF SERVICE er 16, 2016, I electronically fi led the foregoing I hereby certify that on Novemb PLAINTIFFS’ REPLY TO DEFENDANTS’ RESPONSE TO PLAINTIFFS’ MOTION FOR f Oregon by using the SUMMARY JUDGMENT with the Cler k of the Court for the District o is filing will be sent out to all h Local Rule 5-1. Notice of th CM/ECF system, in accordance wit parties by operation of the Court’ s electronic filing system. Parties may access this filing through the Court’s CM/ECF system. s/ Brent W. Renison Brent W. Renison FOR RESPONSE TO PLAINTIFFS’ MOTION PLAINTIFFS’ REPLY TO DEFENDANTS’ SUMMARY JUDGMENT – Page 11

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