The Petitioner, a financial manager, proposed to establish her own financial consulting company offering financial management, accounting, tax, and educational services to small and medium-sized businesses, startups, and individuals in the United States.

Prong 1 — national importancenot established · dispositive

“the Petitioner has not shown how her services would result in broader implications to her field”

“activities which only benefit the Petitioner's prospective clients, like the offerings outlined in her business plan, would not have broader implications in the field”

“the business plan does not provide sufficient explanation for the basis of these employment projections”

“the letter does not establish how the Petitioner's specific endeavor would broadly impact the field or otherwise lead to substantial economic effects”

“the letters of recommendation provide little probative value in establishing the national importance of the Petitioner's endeavor as they primarily focus on the Petitioner's past experience”

“this relates to the importance of the financial management industry in general, rather than the Petitioner's specific endeavor”

AAO decision text

How the evidence was treated

• business plan · discounted

  “the business plan does not provide sufficient explanation for the basis of these employment projections”

  AAO decision text
• recommendation letter · discounted

  “provide little probative value in establishing the national importance of the Petitioner's endeavor as they primarily focus on the Petitioner's past experience”

  AAO decision text
• other · discounted

  “the expert opinion letter primarily restates several of the claims made by the Petitioner”

  AAO decision text
• contract revenue · discounted

  “she does not support these assertions in the record”

  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
• 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
• 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 noted the appeal itself was independently dismissible under 8 C.F.R. 103.3(a)(1)(v) because the Petitioner failed to specifically identify errors in the Director's decision, but the AAO nevertheless proceeded to address the merits of prong one.

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
• Matter of Caron Int'l
• Matter of D-R-

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