This is an AAO appeal decision — a case denied once and appealed. It shows how the framework is applied; it is not the filing population.
The Petitioner, a global operations and maintenance manager, proposed to establish and implement an advanced lifecycle facility management system integrating predictive maintenance, data-driven risk assessment, and energy management technologies for U.S. energy and industrial facilities.
Field: facility management / energy and industrial sectors · Read the decision (uscis.gov)
EB-2 threshold — addressed
SCOPS found, and AAO did not disturb, that the Petitioner qualifies as an advanced degree professional.
Prong 1 — national importancenot established · dispositive
“The Petitioner's personal statements provide only brief, high-level summaries of her model without adequate details explaining what her system will entail”
“a petitioner's work in an important industry, even one that is the subject of national priorities, is not sufficient, in and of itself, to establish the national importance of the proposed endeavor”
“these claimed impacts are too attenuated and rely more on generalizations about the results of typical business activity”
“many of the letters do reference the Petitioner's work, they are largely conclusory in nature and do not provide a sufficient evidentiary basis for their claims”
“expressions of intent to collaborate do not establish the scale, scope, or broader impact of the endeavor”
AAO decision text
How the evidence was treated
- recommendation letter · discounted
“his opinion is general in nature and does not meaningfully address the details of the Petitioner's specific proposed endeavor”
AAO decision text - business plan · discounted
“she does not articulate, and it is largely unclear, how she will knit these technologies, components, and protocols together”
AAO decision text - contract revenue · discounted
“expressions of intent to collaborate do not establish the scale, scope, or broader impact of the endeavor”
AAO decision text - media · discounted
“they do not establish with specificity how the Petitioner's work would impact these areas to show its national importance”
AAO decision text - other · discounted
“they reflect only broad, high-level information without detail or an explanation for their numbers”
AAO decision text
Where this case turned
- 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 rejected the Petitioner's argument that SCOPS improperly applied a 'classroom teacher' analogy to localize the endeavor, finding instead that the record lacked sufficient specificity and corroboration; AAO expressly declined to reach prongs two and three, citing INS v. Bagamasbad on avoiding advisory findings.
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
- Flores v. Garland
- INA 203(b)(2)
What this case teaches
Analyst reading of the decision text.
Lack of specificity and corroboration: petitioner failed to show how her particular system differed from existing industry tools or that claimed economic/operational impacts were attributable to it beyond her own assertions and generic letters.
Support national importance claims with objective, corroborated evidence linking the specific endeavor's mechanism to quantifiable, broader-than-employer impact—not generalized field value or unverified self-reported metrics.
moderate
economic_growth_generic · us_competitiveness · government_interest · economic_job_creation
person_focused
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