B2 - 180 day calculation

[indusvaley]

My mom has 10 year multiple entry visa to visit US. She visited last year and stayed continuously from Oct 26 2008 to April 22 2009. This is 112 days in 2009. Now she is planning to visit again this year from Oct 30 2009 to Jan 31 2010. She will have stayed less than 180 days in 2009, 175 days to be precise. And she is not going to stay more than 3 months when she enters US in Nov 2009.

Does anyone see any problem with this schedule?

[orion]

What matters is if the PoE officer see a problem with this or not

Well, I dont see a problem, but may get restricted I-94 or asked a couple extra questions. However more time must be spent in home country in a 12 month rolling window. Calendar years dont matter.