The Petitioner, a hemodialysis nurse, proposed to operate a mobile health company providing kidney dialysis and related services (education, monitoring, transportation) via mobile medical units, partnering with hospitals and insurers to reach patients including those in rural areas.

Prong 1 — national importancenot established · dispositive

“this demonstrates the substantial merit of her endeavor, but does not establish its national importance.”

“she has not shown how any prospective impact her company may have on these broad national initiatives would rise to the level of national importance”

“the Petitioner has not demonstrated that her proposed endeavor has significant potential to employ U.S. workers or otherwise offers substantial positive economic effects”

“the record contains inconsistent information pertaining to the Petitioner's employment and financial projects.”

“Generalized conclusory statements that do not identify a specific impact in the field have little probative value.”

“the expert opinion does not establish the endeavor would meaningfully impact these initiatives at a broader level.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “provides little probative value in establishing the national importance of the Petitioner's proposed endeavor”

  AAO decision text
• business plan · discounted

  “they do not establish that her company would operate on a scale rising to the level of national importance”

  AAO decision text
• contract revenue · discounted

  “neither endeavor plan provides sufficient explanation for the basis of these employment projections”

  AAO decision text
• media · discounted

  “this demonstrates the substantial merit of her endeavor, but does not establish its national importance”

  AAO decision text
• funding · ignored

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
• Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact
• Local, not national scope · p1 — impact confined to clients / a region

Notable

AAO not only dismissed the appeal on prong-1 national importance grounds but also affirmatively withdrew the Director's favorable threshold EB-2 finding, noting the Petitioner's own endeavor plans contained internal inconsistencies (revised plan silently dropped services, conflicting revenue/employment projections) that undermined credibility; reserved prongs 2 and 3 as unnecessary under Bagamasbad.

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
• 8 C.F.R. 204.5(g)(1)
• 8 C.F.R. 204.5(k)(2)
• Matter of Caron Int'l
• Matter of D-R-
• Matter of E-M-

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