There are some unrealistic rules in PERM that if DOL enforces them, quite a few reasonable cases will not be legit. Such as evidence to show that employer pays for all expenses of PERM including lawyer fees, and in this specific Fragomen's case, lawyers cannot involve in recruitment process.
I think DOL should target on the historical bodyshop / desishop (or in recent years known to chinese as the new term: ICC) and leave most reasonably legitimate cases like those at Fragoman's alone.