The Petitioner, a former military police officer, proposed to provide private security services, security and search-and-rescue instruction, and act as a U.S. defense-equipment sales representative in Brazil, later adding plans to found a security consulting and training business, '1995 - Security & Training,' in a Florida Opportunity Zone.

Prong 1 — national importancenot established · dispositive

“The provision of security services directly benefits only those individuals or entities availing themselves of the Petitioner's services.”

“But the record contains insufficient documentation to support the Petitioner's projections.”

“The manifest thrust of the Petitioner's claim of eligibility ... comes from the Petitioner's claims regarding the importance of their profession, their past career as a member of the military police in their home country, and their dedication to their field.”

“So we conclude that the Petitioner has not established that their proposed endeavor is of national importance.”

AAO decision text

Prong 2 — well positionednot established

“The record simply does not reflect any progress to achieving the proposed endeavor.”

“the recommendation letters the Petitioner submitted are not material, relevant, or probative evidence in the record of interest or support in the endeavor”

“simply having education, skills, and/or knowledge in isolation do not place a petitioner in a position to advance their proposed endeavor.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the recommendation letters the Petitioner submitted are not material, relevant, or probative evidence in the record of interest or support in the endeavor”

  AAO decision text
• business plan · discounted

  “did not demonstrate a model for the actual activities that the Petitioner has developed or played a significant role in developing”

  AAO decision text
• resume experience · discounted

  “simply having education, skills, and/or knowledge in isolation do not place a petitioner in a position to advance their proposed endeavor”

  AAO decision text
• certification membership · discounted

  “The record contains evidence of the Petitioner's academic record, employment history, and professional recognitions such as awards and certificates.”

  AAO decision text
• awards · discounted

  “professional recognitions such as awards and certificates ... do not place a petitioner in a position to advance their 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
• 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
• Business plan speculative · p2 — projections without a documented basis or steps
• Education alone insufficient · p2 — degrees offered as positioning — credentials are not a track record
• Letters not independent · p2 — letters come from employers and close collaborators, not independent experts
• No progress evidence · p2 — no documented movement toward the endeavor since filing
• Record of success insufficient · p2 — a claimed track record the documents do not establish

Notable

The AAO found that the Petitioner's substantial RFE-stage revisions from 'security instructor' to 'security entrepreneur' were 'troublesome' but ultimately did not constitute a materially different endeavor. The AAO also rejected the Opportunity Zone/job-creation argument for lack of specificity and analogized the Petitioner's personal-security training services to teaching, which Dhanasar found insufficient for national importance.

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. 103.3
• Matter of Caron Int'l
• Matter of Izummi
• Matter of Katigbak
• Matter of L-A-C-
• Matter of Y-B-
• Poursina v. USCIS

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