The Petitioner proposed to develop advanced computer science techniques for information processing and data analysis, with a focus on AI safety, interpretability, and natural language processing, including research on keyphrase extraction, misinformation detection, and human-AI collaboration, to be pursued through her employment as an engineering associate.

Prong 1 — national importancenot established

“it appears that the main benefits of the proposed endeavor will flow to the employer benefitting from the employment duties the Petitioner identifies are the conduit to her performance of her proposed endeavor.”

“Benefits to a specific employer alone, even an employer with a national footprint, are not sufficiently relevant to the question of whether a petitioner's endeavor has national importance.”

“whilst this may demonstrate the substantial merit of the proposed endeavor it does not support or demonstrate its potential prospective impact nationally, or even globally, or through broader implications rising to a level of national importance.”

“Simply proposing an endeavor adjacent to an area of substantial merit or special concern to the United States does not render such an endeavor nationally important as a default.”

“the acknowledged funding was granted by the ARO and NIH respectively to individuals other than the Petitioner.”

AAO decision text

Prong 2 — well positionednot established

“the record does not reflect how the Petitioner's prior performance of the duties described in the experience letters and a manuscript for a paper in process as either a similar effort as that of her proposed endeavor or how it constitutes a record of success.”

“The letters largely speak effusively of the Petitioner's work ethic, demeanor, or representations of her skill or experience in common interactions.”

“the Petitioner has not persuasively established that the propositions the citations stand for are connected to the endeavor she plans to undertake and therefore how citation by 'independent research teams all over the world' supports how well she is positioned to advance her proposed endeavor.”

“simply having education, skills, and/or knowledge, or even maintaining employment wherein the activities contemplated of a proposed endeavor may be performed does not definitively place a petitioner in a position to advance his or her proposed endeavor.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the letters overwhelmingly described the work she did previously... making general conclusory statements without adequate support in the record”

  AAO decision text
• citations publications · discounted

  “the Petitioner has not persuasively established that the propositions the citations stand for are connected to the endeavor she plans to undertake”

  AAO decision text
• funding · discounted

  “the acknowledged funding was granted by the ARO and NIH respectively to individuals other than the Petitioner”

  AAO decision text
• other · discounted

  “although these articles contributed to demonstrating the importance of the field within which the Petitioner occupies space, they do not demonstrate the national importance of the Petitioner's specific work”

  AAO decision text
• resume experience · discounted

  “the evidence the Petitioner submitted is not material, relevant, or probative evidence in the record of a similar effort as that of her proposed endeavor or how it constitutes a record of success”

  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
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Funding absent · p1 — no documented funding or resources behind the plan
• Citations insufficient · p2 — citation counts without qualitative account of impact
• Letters conclusory · p2 — letters praise skills in general terms without tracing specific impact
• No progress evidence · p2 — no documented movement toward the endeavor since filing
• Record of success insufficient · p2 — a claimed track record the documents do not establish

Notable

The AAO sua sponte withdrew SCOPS' favorable prong 2 finding and independently found prong 2 not met, despite the appeal being filed by the Petitioner. The decision includes an unusual footnote (fn. 4) clarifying that there is no requirement that an endeavor be 'innovative' or 'distinct' or have 'broad, far-reaching' implications — framed as a correction of potential over-reading of Dhanasar. The Petitioner's own signed statement acknowledging her endeavor is pursued through her employer's proprietary software development was used against her to establish employer-specific benefit. The AAO also noted an apparent internal inconsistency in the Petitioner's appeal brief, which simultaneously called SCOPS' substantial merit finding 'indefensible' and argued the evidence established substantial merit.

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