Argument specification II uses A, B, and C once each. Apart from
these three letters, it uses I, J, and K up to 10 times each (i.e., 10 independent
sets of I, J, and K are used). Thus, it can pass initial values to
all the 33 local variables.
I can post more details if you are interested.
You seem to be familiar with argument specification I only. In this method, L, O, N, G, and P cannot be used for passing variable. (I remember this as LONG Program)