The Petitioner, a Brazilian former customer care manager with 17 years of experience, proposed to provide commercial management consulting services to U.S. businesses—covering customer relations, strategic planning, team management, and 'endomarketing'—either through her own company or by working for an established U.S. firm.

Prong 1 — national importancenot established · dispositive

“The record, however, does not sufficiently establish that the Petitioner's proposed endeavor has national importance.”

“She has not demonstrated that the scope of her commercial management services would be broad enough to affect the national economy.”

“If she decides to establish her own company, the record lacks a business plan providing her business's projected revenues and its number of employees and customers.”

“Neither expert explains how the Petitioner's particular proposed endeavor has national importance.”

“But they do not explain how her specific proposal - by itself - has national implications for the economy or her field.”

“she has not demonstrated that her particular activities would "more broadly" affect the U.S. economy or the commercial management field.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “Neither expert explains how the Petitioner's particular proposed endeavor has national importance.”

  AAO decision text
• business plan · discounted

  “the record lacks a business plan providing her business's projected revenues and its number of employees and customers.”

  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
• 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
• Local, not national scope · p1 — impact confined to clients / a region

Notable

AAO explicitly analogized the case to Dhanasar's own facts (the STEM-teaching petitioner), holding the Petitioner's consulting proposal similarly failed to show broader field-wide impact despite having substantial merit.

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. 204.5(k)(2)
• INA 203(b)(2)
• Matter of L-A-C-

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