The FAM states that time as an L-2 dependent does not count against the principal L-1 maximum. The person must still independently meet the requirements for the proposed principal classification.
Keep status history and current rights distinct
Qualifying L spouses are employment authorized incident to status with appropriate documentation; children receive no work permission solely through L dependent status. A later principal application requires its own employment, knowledge and company analysis. Establish the person’s own status for each period before considering what the periods add up to, because dependent time and principal time are not established by the same documents.
The practical consequence of the FAM position is that dependent periods must be provable rather than merely asserted: keep the dependent approval or the record of admission showing the classification, not simply a recollection that the family travelled together. Someone who moved between dependent and principal status more than once should document each transition on its own, since those changeovers are where a chronology usually loses its footing. A later principal application still requires its own employment, knowledge and company analysis, and the fact that earlier time does not count against the maximum says nothing about whether the new role qualifies.
Where a dependent period cannot be evidenced at all, say so before anyone relies on the analysis, since a period that cannot be proved is a different problem from a period that counts against the maximum.