My girlfriend visited me on a B2 VISA back in 27 May this year. She stayed for 9 days. Then she visited me again July 1st and stayed for almost 3 months for the summer. She left the US in Sep 26 this year. She wants to come back to spend thanksgiving and Christmas with me, probably coming here around Nov 15. It goes without saying that she has no intention of working here and has come here just to see me ( I live and work in New York city and go frequently to see her as well, we're both financially comfortable). We're both brazilians.

The question is, does she run any risk of being denied entry, and how to minimize such risks?