The Petitioner, a Brazilian legal consultant, proposed to expand his law-consultancy business into the United States (targeting California, Utah, and Arizona SBA HUBZones) to help U.S. and foreign companies with cross-border legal and trade matters.

Prong 1 — national importancenot established

“we do not agree with the Director's determination that the endeavor has national importance.”

“The Petitioner has not demonstrated that the endeavor he proposes to undertake has significant potential to employ U.S. workers”

“the growth forecast figures do not appear to originate from objective sources”

“the record does not show that the Petitioner's proposed endeavor stands to sufficiently extend beyond his company and its clientele”

AAO decision text

Prong 2 — well positionednot established · dispositive

“Letters submitted as evidence of the Petitioner's work experience following his bachelor's degree provide only an overview of his duties.”

“they do not elaborate on the services provided or illuminate any specific accomplishments”

“these letters are non-committal and only generally refer to the Petitioner's interest in providing legal services in the United States”

“the record does not include documentation to demonstrate the availability or existence of these investment funds”

“the details in the record concerning the Petitioner's legal and entrepreneurial accomplishments are found almost entirely within documentation generated by the Petitioner or his attorney”

AAO decision text

How the evidence was treated

• business plan · discounted

  “the growth forecast figures do not appear to originate from objective sources”

  AAO decision text
• recommendation letter · discounted

  “they do not elaborate on the services provided or illuminate any specific accomplishments”

  AAO decision text
• resume experience · discounted

  “found almost entirely within documentation generated by the Petitioner or his attorney”

  AAO decision text
• funding · discounted

  “the record does not include documentation to demonstrate the availability or existence of these investment funds”

  AAO decision text
• other · discounted

  “this information does not provide probative evidence that the Petitioner is well positioned to advance his 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
• Local, not national scope · p1 — impact confined to clients / a region
• Funding absent · p2 — no documented funding or resources behind the plan
• Letters conclusory · p2 — letters praise skills in general terms without tracing specific impact
• Letters not independent · p2 — letters come from employers and close collaborators, not independent experts
• Record of success insufficient · p2 — a claimed track record the documents do not establish

Notable

Petitioner's business plan relied on the SBA HUBZone program framing to argue economic-development benefits, which the AAO found unsupported by objective sourcing or evidence of investment funds availability.

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 L-A-C-
• Poursina v. USCIS

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