The petitioner initially proposed working as a general and operations manager advising U.S. companies on planning, directing, and coordinating operations, particularly for international business; she later described operating her own consulting firm connecting U.S. and Turkish companies.

Prong 1 — national importancenot established · dispositive

“the record does not sufficiently show that the benefits resulting from the Petitioner's work would impact the industry beyond the immediate benefits provided to her potential employers or customers.”

“any benefits derived from the Petitioner's services would be limited to her immediate customers rather than resulting in broader implications to the field.”

“the business plan provides little explanation and objective basis of these projections”

“As the research cited in the Petitioner appellate brief discussing the economic impact of immigrant entrepreneurs does not discuss the Petitioner nor her plans to work as a general and operations manager, they are do not establish the national importance of her endeavor.”

“she has not demonstrated that her specific proposed endeavor has significant potential to employ U.S. workers or otherwise offer substantial positive economic effects.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the letters of recommendation do not analyze the Petitioner's specific proposed endeavor or offer evidence of its impact, beyond commenting on her expertise.”

  AAO decision text
• other · discounted

  “the letter does not address the broader implications that would be directly attributable the Petitioner's work”

  AAO decision text
• business plan · discounted

  “does not establish the national importance of her endeavor as any benefits derived from the Petitioner's services would be limited to her immediate customers”

  AAO decision text
• media · discounted

  “we focus on the broader implications of the specific endeavor... rather than the industry or the collective impact of entrepreneurs.”

  AAO decision text
• contract revenue · discounted

  “the business plan provides little explanation and objective basis of these projections”

  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
• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• 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

AAO withdrew the Director's finding on substantial merit but still found national importance unmet; also found the petitioner's RFE-stage business plan constituted an impermissible material change under Matter of Izummi, and deemed the issue waived on appeal since petitioner did not contest it, though AAO alternatively analyzed the business plan's insufficiency in dicta.

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.

• 8 C.F.R. 204.5(k)(2)
• Flores v. Garland
• Matter of Caron Int'l
• Matter of D-R-
• Matter of E-M-
• Matter of Izummi
• Matter of Katigbak
• Matter of L-A-C-
• Matter of O-R-E-
• Matter of R-A-M-

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