I have heard that there is. But here is the problem, NAI is already an certified as an Irish airline, so it is a bit difficult to argue that an (officially) Irish Airline, flying to and from Ireland, is doing so to avoid Irish labor laws.

Here is the other issue - the DOT has already issued AOCs to foreign airlines that use contract pilots. Air China, China Eastern, China Southern, Hainan, Sichuan, Korean Air, Asiana, Eva Air, and China Airlines are all examples of airlines that operate to and from US territory and use pilots contracted through agencies based in third countries.

So based on the letter of the law and historical precedent it would seem that denying NAI would open a big legal firestorm.

I agree with all of the arguments that are being made about the potential consequences of NAIs scheme. In fact I have seen the negative effects wrought by Norwegian's business practices up close and very personal - as in they have directly effected my family. So by no means am I a defender of the "Red Nosed Devil". But the arguments against them need to be sound arguments, not based on false assumptions and incorrect facts.