The Petitioner, a financial manager, proposed to provide financial management, strategic business planning, accounting, and consulting services to businesses and the banking sector, including helping Latin American companies enter the U.S. market and U.S. companies expand into Brazil, using tools like data analytics, AI, and blockchain.

Prong 1 — national importancenot established · dispositive

“the industry alone is not sufficient to establish its national importance”

“the record does not establish how the Petitioner will impact the industry beyond the immediate benefits she may provide to her prospective employers or customers”

“the record does not contain provided projected employment numbers and revenue growth contributable to her specific endeavor”

“Generalized conclusory statements that do not identify a specific impact in the field have little probative value.”

“activities which only benefit the Petitioner's customers or prospective employers would not result in broader implications in the field”

AAO decision text

How the evidence was treated

• business plan · discounted

  “does not establish how the Petitioner will impact the industry beyond the immediate benefits she may provide to her prospective employers or customers”

  AAO decision text
• recommendation letter · discounted

  “primarily focus on the Petitioner's past experience without addressing the prospective impact of her endeavor”

  AAO decision text
• other · discounted

  “the industry alone is not sufficient to establish its national importance”

  AAO decision text

Where this case turned

• 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
• 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

Notable

AAO explicitly disagreed with the Director on substantial merit (found it established via industry articles) but agreed on national importance, illustrating the AAO's practice of splitting the two sub-elements of prong 1. AAO reserved prongs 2 and 3 as unnecessary under Bagamasbad.

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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