The Petitioner initially proposed to work as a management specialist and human resources expert serving small and medium enterprises, then materially changed her proposed endeavor to operating an online store selling greeting cards, gifts, and photo albums.

Prong 1 — national importancenot established · dispositive

“The Petitioner provided background information about the importance of small businesses, but did not offer any further details about her proposed endeavor.”

“The Petitioner cited no supporting evidence to establish that operating an online greeting card store would have national imp01iance in this way.”

“The Petitioner did not explain how this level of projected employment represented significant potential to employ U.S. workers or would have other substantial positive economic effects.”

“the submitted letter is questionable because it includes general references to expertise and experience as an executive and as a greeting card entrepreneur, without citing to any evidence”

“A business plan in the record appears to be based on a general template.”

AAO decision text

How the evidence was treated

• business plan · discounted

  “A business plan in the record appears to be based on a general template.”

  AAO decision text
• recommendation letter · discounted

  “the submitted letter is questionable because it includes general references to expertise and experience...without citing to any evidence that the Petitioner actually possesses that expertise or experience”

  AAO decision text
• degree · discounted

  “she has neither shown nor claimed that operating an online store requires at least a bachelor's degree”

  AAO decision text
• motion resubmission · discounted

  “the brief repeats, verbatim, a statement originally submitted in response to the Director's request for evidence”

  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
• Endeavor too vague · p1 — described as a job role, not a defined undertaking
• Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact

Notable

The Petitioner made a substantial material change to her proposed endeavor after filing—from working as a management/HR consultant to operating an online greeting card store—which the AAO noted was impermissible under Matter of Izummi, though it nonetheless addressed the revised endeavor's merits since the Director's denial was based on it. The AAO also noted a separately filed, later petition with the revised endeavor had been approved, but declined to consider its effect on this appeal.

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. 103.2(b)(1)
• 8 C.F.R. 204.5(k)(2)
• Matter of D-R-
• Matter of Izummi
• Matter of L-A-C-
• Poursina v. USCIS

Cases in adjacent profiles

• The Beneficiary proposed to establish an asset investment management and compliance advisory firm in New York offering c
• The Petitioner proposed to develop and commercialize zeolite-based products in the United States, including agricultural
• The Petitioner proposed to operate a medical billing and healthcare revenue cycle management firm in the United States,
• The Petitioner proposed to establish and lead as CEO a cybersecurity and crisis management company in Florida, offering
• The Petitioner proposed to establish and operate an IT consultancy company in Michigan providing cloud migration, cybers