The Petitioner proposed to provide regulatory-affairs and quality/compliance training and consulting to medical device manufacturers through her own Maryland-based company, while also working as a regulatory affairs manager for a U.S. medical device employer.

Prong 1 — national importancenot established · dispositive

“a shortage of workers within a given occupation does not render a proposed endeavor nationally important under the Dhanasar framework”

“the business plan by itself does not sufficiently detail the basis for its financial and staffing projections”

“The Petitioner has not provided corroborating evidence as to how the Company's activity stands to provide "substantial economic benefits" in the United States”

“they do not show that her endeavor or methodologies will impact more than just the clients and companies she will serve”

“merely working in an important field or profession is insufficient to establish the national importance of the proposed endeavor”

“even if the Company were to provide jobs in a HUBZone location, the number of projected jobs is not sufficiently high to be considered of national importance”

AAO decision text

How the evidence was treated

• business plan · discounted

  “the business plan by itself does not sufficiently detail the basis for its financial and staffing projections”

  AAO decision text
• recommendation letter · discounted

  “the letter, on the whole, does not bolster the national importance of her endeavor because it touches on different concerns”

  AAO decision text
• resume experience · discounted

  “they do not demonstrate the national importance of her endeavor's "potential prospective impact."”

  AAO decision text
• media · discounted

  “they do not discuss the Petitioner's proposed endeavor or explain how her endeavor would have broader implications”

  AAO decision text
• degree · credited

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
• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Local, not national scope · p1 — impact confined to clients / a region
• Occupational shortage argument rejected · p1 — argues a labor shortage — the labor-certification question, not Dhanasar

Notable

AAO rejected Petitioner's unsupported claim that the Director imposed 'novel substantive and evidentiary requirements' or an improper standard of proof, finding the Director's NOID properly followed 8 C.F.R. 103.2(b)(8). AAO also specifically analyzed and rejected the HUBZone-based economic-impact argument, finding no evidence of HUBZone certification eligibility and that even qualifying job numbers were too small to be nationally important.

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)(8)
• 8 C.F.R. 103.3
• 8 C.F.R. 204.5(k)(2)
• Matter of E-M-
• Matter of L-A-C-
• USCIS Policy Manual F.5(D)(1)
• USCIS Policy Manual F.5(D)(2)

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