The Petitioner, a treasurer and controller, proposed to work with U.S. companies across various industries applying his financial and controllership expertise to develop financial policies, negotiate debts, and improve profitability.

Prong 1 — national importancenot established · dispositive

“we conclude that the Petitioner has not sufficiently demonstrated the national importance of his proposed endeavor under the first prong of the Dhanasar analytical framework”

“we conclude that the Petitioner has not provided a specific or consistent proposed endeavor activity such that we can determine its national importance”

“Moreover, it is important to note that the shortage of business professionals does not render his proposed endeavor nationally important under the Dhanasar framework”

“in determining national importance, the relevant question is not the importance of the industry or profession in which the individual will work”

“Neither the letters nor any other evidence within the record provide insight into how the Petitioner's endeavor...will positively impact the region or the industry beyond his employers and their clients”

“These materials do not specifically describe the Petitioner's proposed endeavor or its potential impact, but rather amount to background information about general subjects”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “neither author discussed the Petitioner's specific proposed endeavor”

  AAO decision text
• resume experience · discounted

  “they are immaterial to the first Dhanasar prong, which pertains to whether the prospective endeavor has both substantial merit and national importance”

  AAO decision text
• other · discounted

  “these articles and reports provide useful background information...but do not specifically describe the Petitioner's proposed endeavor or its potential impact”

  AAO decision text
• degree · discounted

  “the Petitioner's reliance throughout the record on his academic achievements and prior employment history is misplaced”

  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 not independent · p1 — letters come from employers and close collaborators, not independent experts
• 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

The AAO explicitly declined to reach prongs 2 and 3 as well as the underlying threshold EB-2 classification issue (which the Director also had not decided), resting the dismissal entirely on prong 1's national importance requirement due to a vague, multi-field endeavor description.

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
• Matter of E-M-
• Matter of L-A-C-

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