The Petitioner proposed to conduct research developing graph-based deep learning models for link prediction, with applications in large language models, fraud detection in financial systems, social media content optimization, and e-commerce recommendation systems. He intended to pursue this research through employment in private industry or academia while publishing scholarly articles and presenting at conferences.

Prong 1 — national importancenot established · dispositive

“it appears that the main benefits of the proposed endeavor will flow to the employer, such as... benefits to a specific employer alone, even an employer with a national footprint, are not sufficiently relevant”

“whilst this may demonstrate the substantial merit of the proposed endeavor it does not support or demonstrate the potential prospective impact nationally, or even globally”

“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 record does not indicate details about the grant funding, such as the purpose, amount, mission, or even the recipient such that we could evaluate the Petitioner's claims”

“the articles do not demonstrate the national importance of the Petitioner's specific work.”

“the letters mainly provide general summaries of his previous research projects without mentioning or describing his proposed endeavor”

AAO decision text

Prong 2 — well positionednot established

“he has not demonstrated that he has made progress towards achieving the specific proposed endeavor or has established interest in his future research.”

“the letter from... speaks effusively of the Petitioner's skill and work and the importance of his field, it does not adequately explain how this would serve to position him well to advance the specific endeavor”

“he has not shown that he was primarily responsible for securing the funding for the research projects.”

“the overwhelming majority of the publications that he is credited with were published whilst he was completing his undergraduate or graduate studies.”

“aside from the Petitioner's own statements, the record does not contain sufficient documentation supporting his plans for his proposed endeavor.”

AAO decision text

How the evidence was treated

• resume experience · discounted

  “the work experience letter contained in the record is not sufficient to evaluate whether the Petitioner has gained at least five years of progressively responsible post-baccalaureate work experience”

  AAO decision text
• recommendation letter · discounted

  “the letters mainly provide general summaries of his previous research projects without mentioning or describing his proposed endeavor”

  AAO decision text
• citations publications · discounted

  “the overwhelming majority of the publications that he is credited with were published whilst he was completing his undergraduate or graduate studies.”

  AAO decision text
• other · discounted

  “the articles do not demonstrate the national importance of the Petitioner's specific work.”

  AAO decision text
• funding · discounted

  “the record does not indicate details about the grant funding, such as the purpose, amount, mission, or even the recipient”

  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
• Funding absent · p2 — no documented funding or resources behind the plan
• 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

Unusually, the AAO both dismissed the appeal on prong 1 (national importance) AND affirmatively withdrew SCOPS' favorable prong 2 finding, concluding the petitioner was also NOT well-positioned — a double reversal against the petitioner. The AAO also withdrew SCOPS' threshold EB-2 finding, identifying a conflict between the university employment letter (August 2019–December 2024) and the ETA-9089 (three discrete summer internship periods totaling less than five years), and noting the employment was part-time. The petitioner cited Buletini v. INS to argue abuse of discretion, which the AAO addressed directly by reaffirming that SCOPS applied a reasoned, quality-based evidentiary analysis. The AAO explicitly reserved prong 3 under INS v. Bagamasbad. The decision is handled by SCOPS (Service Center Operations) rather than a named service center.

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