The Petitioner, a clinical laboratory technician, initially proposed to work as a healthcare professional in underserved shortage areas, and later expanded her endeavor to establishing her own company providing clinical laboratory testing and blood-component quality control services to clinics, hospitals, and health centers.

Prong 1 — national importancenot established · dispositive

“the Petitioner's evidence consists of general articles discussing the shortage of healthcare professionals in various parts of the United States and did not include any details and specific impact of her endeavor”

“The Petitioner generally claims that health professionals bring "positive effects on the nation's economy and productivity," but has not supported her claims with pertinent evidence”

“We agree with the Director that the Petitioner has not established that her company would operate on such a large scale that would benefit the U.S. economy rising to the level of national importance.”

“None of the articles specifically address the Petitioner's endeavor or discuss the government's interest in promoting the use of the Petitioner's company.”

“we emphasize that such evidence does not necessarily establish the national importance of the Petitioner's proposed endeavor under the first prong of the Dhanasar framework”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the letter discusses the Petitioner's past participation in the professor's health technology classes... instead of addressing the Petitioner's specific future endeavor and its broad impact”

  AAO decision text
• other · discounted

  “such evidence does not necessarily establish the national importance of the Petitioner's proposed endeavor under the first prong of the Dhanasar framework”

  AAO decision text
• business plan · discounted

  “the Petitioner has not established that her company would operate on such a large scale that would benefit the U.S. economy rising to the level of national importance”

  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
• 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

A footnote highlights that the Director's decision inconsistently found the Petitioner qualified for the EB-2 classification despite prior RFEs concluding she did not meet the advanced degree or exceptional ability criteria; the AAO expressly reserved this threshold eligibility question rather than resolving it, since the appeal was dismissed on prong one alone.

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
• 8 C.F.R. 204.5(k)(3)(ii)
• Flores v. Garland
• Matter of L-A-C-
• USCIS Policy Manual F.5(D)(1)
• USCIS Policy Manual F.5(D)(2)

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