Your analysis is based on May 2005 Yates' memo, where Yates overthrowed his own 2003 memo narrow view on H1B 7th year extention.
However on the issue of your
"2) At the time of your requested 7th-year extension, you should be in a valid H-1B status"
Aytes's 2006 memo should be the new current guidance which supercedes Yates 2005 memo on this issue. Aytes's 2006 memo says that you don't need to be currently in H1 status to get H1 extension beyond 6th year. This change is important because many Indians (and Chinese) who were using c9 EAD (after using up H1 6 years) have benefited from this guidance to get their spouses into US in H4.
However on the issue of your
"2) At the time of your requested 7th-year extension, you should be in a valid H-1B status"
Aytes's 2006 memo should be the new current guidance which supercedes Yates 2005 memo on this issue. Aytes's 2006 memo says that you don't need to be currently in H1 status to get H1 extension beyond 6th year. This change is important because many Indians (and Chinese) who were using c9 EAD (after using up H1 6 years) have benefited from this guidance to get their spouses into US in H4.
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