Figure B

HCL ‘carefully constructs’ its H-1B pool to favor jobs with widest wage gap between H-1B workers and U.S. citizens and permanent residents: Image of part of slide in internal HCL Technologies document explaining its rationale for choosing which jobs it seeks to fill by applying for H-1B visas ("nominations")

HCL ‘carefully constructs’ its H-1B pool to favor jobs with widest wage gap between H-1B workers and U.S. citizens and permanent residents: Image of part of slide in internal HCL Technologies document explaining its rationale for choosing which jobs it seeks to fill by applying for H-1B visas (

Note: Yellow highlighting added by authors.

Source: Adapted from HCL, “Guidelines for H1 nominations,” Exhibit 57. Case 3:19-cv-01185-MPS Document 48-57, filed September 7, 2021, at page 2. From United States of America, ex rel. Ralph Billington, Michael Aceves, and Sharon Dorman (Plaintiffs) v. HCL Technologies LTD. and HCL America, INC. (Defendants). Fourth Amended Complaint for Violations of the False Claims Act. United States District Court for the District of Connecticut. Civil Action No. 3:19-CV-1185 (MPS).

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