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Most states don't actually have a COMLEX failure cap or combine attempts from all 3. FSMB | State Specific Requirements for Initial Medical LicensureI think most states also allow licensure up to 3 attempts per step. If OP lives in a state where they allow that or more tries, he may use that as an argument. I also had a friend that failed level multiple times. He got a letter from a psychiatrist and that's what the school accepted to allow him to take again