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By his reference to start dates, I'm guessing he means that the start date/time had not passed yet, which makes sense if you think about it.

Mind you, I'm having a similar problem in reverse.... Unavailable actions still show up in the "Due Soon" category and on the numeric badge on the home screen. So if I have a project with 15 sequential actions listed, and the project itself is "Due Soon" ALL of these actions show up individually under "Due Soon" even though they obviously aren't all available and still need to be completed in a specific order.

With several projects that are structured in this way, it wreaks havoc with the badge count... I have hundreds of "Due Soon" tasks....