Is working under 2nd masters considered as Unlawful presence ?

[ash22]

Is working under 2nd masters considered as Unlawful presence as per the new memorandum effective from Aug 9th 2018 ?

I think it does not directly imply the same. Thoughts ?

https://www.uscis.gov/sites/default/files/USCIS/Outreach/Draft%20Memorandum%20for%20Comment/AccrualofUnlawfulPresenceFJMNonimmigrantsMEMO_v2.p df

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