The Petitioner, a supply chain analyst, proposed to work for an organic food company performing transportation route planning and log-truck scheduling optimization to improve the efficiency of the company's logistics operations.

Prong 1 — national importancenot established · dispositive

“the Petitioner had not identified her proposed endeavor with adequate specificity or consistency to demonstrate that it has substantial merit and national importance”

“the Petitioner has not established that her proposed work for has implications beyond her company and its customers at a level sutlicient to establish the national importance of her endeavor.”

“the record does not show that the specific work she proposes to undertake offers original innovations that advance the industry, or otherwise has broader implications in the supply chain management field.”

AAO decision text

Prong 2 — well positionedestablished

“The evidence discussed above is sutlicient to demonstrate that the Petitioner is well positioned to advance her proposed endeavor of analyzing Pulmuone's logistical operations.”

AAO decision text

How the evidence was treated

• recommendation letter · credited
• resume experience · credited
• citations publications · discounted

  “she has not identified conducting and publishing academic research as her proposed endeavor”

  AAO decision text
• contract revenue · discounted

  “has not established that her proposed work for has implications beyond her company and its customers”

  AAO decision text

Where this case turned

• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• Endeavor too vague · p1 — described as a job role, not a defined undertaking
• Local, not national scope · p1 — impact confined to clients / a region
• Derivative of Prong 1/2 failure · p3 — prong three fails only because prongs one or two did — no independent ground

Notable

The Petitioner's proposed endeavor shifted multiple times across the record (search engine optimization research, mathematical statistician for a healthcare company, statistical analysis/optimization in IT, and finally supply chain analyst for an organic food company), which the AAO cited as undermining specificity despite noting the Director's improper focus on lack of a 'definitive' job offer under Dhanasar. The AAO also faulted the Director's NYSDOT-era RFE language even though it ultimately applied the Dhanasar framework throughout its own analysis.

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.

• INA 203(b)(2)

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