I understand what you said. I did a lot of research and also consulted the DSO in my school. The DSO in our school is a law expert who served for the department of justice for over 35 years. from his interpretation he approved my application. somewhere else I read some requirement for a 2nd OPT,
1. higher degree OR
2. leave USA for 5 months OR
3. in US, you changed to other visa for over 1 year.
We should make it clear. it will help all of us a lot. I wishes we could find some people in same situation. The best answer is the application result from similar cases.