This is an AAO appeal decision — a case denied once and appealed. It shows how the framework is applied; it is not the filing population.
The Beneficiary, employed as a Senior MLOps Engineer at an AI-powered welding and industrial automation company, proposed to scale and optimize machine learning workflows for autonomous welding and fabrication systems, with asserted broader impacts on U.S. manufacturing, labor shortages, and national security.
Field: applied machine learning and artificial intelligence / MLOps engineering · Read the decision (uscis.gov)
EB-2 threshold — addressed
SCOPS and AAO both agreed the Beneficiary qualifies as an advanced degree professional; threshold EB-2 was not at issue.
Prong 1 — national importancenot established · dispositive
“the Petitioner's wide-ranging assertions as to potential prospective national impact crossing numerous industries and societal issues leaves substantial question as to whether the Beneficiary's proposed work with the company would have a significant impact on any of them.”
“Benefits to a specific employer alone, even an employer with a national footprint, are not sufficiently relevant to the question of whether a person's endeavor has national importance.”
“it is not clear whether the Beneficiary's claimed innovations would be owned and/or controlled by her employer and whether she would be granted permission to disseminate this information.”
“its overall significance does not establish the national importance of the Beneficiary's particular proposed endeavor.”
“the article she co-authored with several others was cited only 10 times as of the time the petition was filed.”
“There is also little indication that there is specific interest from the U.S. government regarding the advancement of Beneficiary's work”
AAO decision text
How the evidence was treated
- recommendation letter · discounted
“these did not support the impact of the Beneficiary's proposed endeavor on her field.”
AAO decision text - citations publications · discounted
“the article she co-authored with several others was cited only 10 times as of the time the petition was filed.”
AAO decision text - resume experience · discounted
“the Petitioner submitted little evidence to substantiate that the Beneficiary stands significantly apart from her colleagues both within the company and in the field.”
AAO decision text - other · discounted
“Generalized conclusory statements that do not identify a specific impact to the field have little probative value.”
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
- Local, not national scope · p1 — impact confined to clients / a region
Notable
SCOPS found prong 2 satisfied (Beneficiary well-positioned) but denied on prong 1; AAO affirmed the prong 1 failure as dispositive and expressly reserved prong 3. The AAO also noted a procedural deficiency — the appeal merely reiterated prior assertions without identifying specific errors of fact or law, citing Matter of Valencia and Matter of Garcia, and stated this alone was grounds for dismissal, though it proceeded to analyze the merits anyway. The decision contains a likely drafting error in the conclusion: 'we conclude that he has not established she is eligible,' mixing pronouns for the Beneficiary. The Beneficiary had been employed only about two months before the petition was filed (November 2024 hire, January 2025 filing), which the AAO cited skeptically against the 'pivotal role' assertion.
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