The Petitioner, a human resources specialist with about 10-15 years of experience, proposed to continue HR work for U.S. organizations and eventually develop her own human resources consulting firm in Florida focused on reducing employee turnover and operational costs for U.S. companies.

Prong 1 — national importancenot established · dispositive

“The Petitioner's initial description of the proposed endeavor does not provide any other details beyond her intention to continue working as a human resources specialist for unidentified U.S. organizations and businesses.”

“merely working in an important field is insufficient to establish the national importance of the proposed endeavor.”

“the business plan by itself does not sufficiently detail the basis for its financial and staffing projections, or adequately explain how these projections will be realized.”

“the industry reports and articles submitted do not discuss any projected U.S. economic impact or job creation specifically attributable to the Petitioner's proposed endeavor.”

“the Petitioner does not demonstrate that her proposed endeavors extend beyond her future clients or employers, to impact the field or any other industries or the U.S. economy more broadly at a level commensurate with national importance.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “these documents relate to the second prong of the Dhanasar framework”

  AAO decision text
• resume experience · discounted

  “only address her past accomplishments as a human resources professional impacting her workplace and do not address national importance”

  AAO decision text
• business plan · discounted

  “the business plan by itself does not sufficiently detail the basis for its financial and staffing projections”

  AAO decision text
• other · discounted

  “Where an opinion is not in accord with other information or is in any way questionable, USCIS is not required to accept it or may give it less weight.”

  AAO decision text
• other · discounted

  “merely working in an important field is insufficient to establish the national importance of the proposed endeavor”

  AAO decision text

Where this case turned

• Business plan speculative · p1 — projections without a documented basis or steps
• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Endeavor too vague · p1 — described as a job role, not a defined undertaking
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Local, not national scope · p1 — impact confined to clients / a region

Notable

The AAO highlighted that the Petitioner's own business plan showed most project milestones (company incorporation, branding, bank account, initial investment) as 'on hold' or 'not started,' with only 'obtain visa for owner' met—undercutting the plan's credibility, though this was noted in a footnote rather than under a formal prong 2 analysis since the AAO declined to reach prongs two and three after finding prong one dispositive.

Authorities this decision leans on

From the doctrinal survivor set — 187 authority tests across 47 distinct authorities cleared the differential-lift gates. Only those appear here.

• Matter of E-M-
• Matter of L-A-C-
• Poursina v. USCIS

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