Thus, Halliday asked, how will this electronic system "be safeguarded from potential abuses such as 'stuffing' the electronic registration system with huge numbers of speculative H-1B cases to hedge their bets for a number; or other unfair 'gaming' of the H-1B registration process system?"

In an interview, Halliday likened the registration system to music fans that "buy all the front row tickets to a rock concert."

The American Immigration Lawyers Association is warning that the system will create a rush of registrations and "generate false H-1B demand" by "creating a flood of unnecessary or unqualified registrations, potentially numbering in the thousands, that will ultimately be abandoned or denied."

It's expected that the USCIS will set up this electronic registration period each March, just prior to the April 1 start date for new fiscal year applications. The lawyers association said that the proposal presupposes that employers will have completed work on projecting staffing levels needed for the entire U.S. fiscal year.

The USCIS projects that the new rules would save employers some $24 million in preparation costs over the next 10 years.