As you said yourself, the manual states that proper fill is between the L and H marks. It does not say half-way between, so the common interpretation is that safe operation is anywhere between the marks. Given that the vehicle likes to consume oil, filling as close as possible to the H mark without going over is always going to be the safest approach long term. However in using this technique you have to give plenty of time for the oil to drain to the bottom of the pan to get an accurate reading.
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