NIW Bearings
dismissedJAN232024_05B52032024-01-23 · appeal · Texas Service Center

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 Petitioner, an energy systems engineer with a 2022 doctorate, sought to work in solar-thermal and related energy technologies, later claiming he would start a company manufacturing and selling high-performance energy systems.

Field: energy systems engineering · Read the decision (uscis.gov)

EB-2 threshold — addressed

Director concluded, and record supported, that Petitioner qualifies as an EB-2 advanced degree professional based on a foreign degree equivalency.

Prong 1 — national importancenot established · dispositive

he has not specified whether he will work as a researcher or start an energy systems business, or how he will divide his time between these activities
the changes the Petitioner made to his proposed endeavor in response to the Director's RFE are material to his eligibility under the first Dhanasar prong
The patent application ... is dated May 2023, as is the funding pledge letter
the Petitioner has not provided sufficient information about his endeavor to establish that it will "probably" farther human knowledge

AAO decision text

How the evidence was treated

  • recommendation letter · discounted
    The recommendation letters ... do not relate specifically to his proposed endeavor
    AAO decision text
  • business plan · discounted
    the revised endeavor is a material change made after filing and will not be accepted
    AAO decision text
  • patents · discounted
    The patent application ... is dated May 2023, as is the funding pledge letter
    AAO decision text
  • funding · discounted
    These documents also date from after the Director's April 2023 RFE
    AAO decision text
  • degree · discounted
    these credentials relate to the second Dhanasar prong ... do not relate to whether that endeavor would have substantial merit
    AAO decision text
All 6 evidence items
  • resume experience · discounted
    his work and publication history as a research assistant ... relate to the second Dhanasar prong
    AAO decision text

Where this case turned

  • Business plan speculative · p1projections without a documented basis or steps
  • Endeavor too vague · p1described as a job role, not a defined undertaking
  • Material change of endeavor · p1the endeavor described on appeal is not the one filed
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Notable

The AAO found the appeal independently dispositive on a non-substantive ground: the Petitioner never submitted the required DOL Form ETA-750B (or ETA-9089 Parts J/K/L) despite being told to do so in the RFE and denial, and waived the issue by not addressing it on appeal. The AAO also applied the material-change doctrine (Matter of Izummi/Katigbak) to reject a business-plan-based endeavor first raised in RFE response as differing materially from the initial filing, which described only a vague job search.

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. 103.2(b)(1)
  • 8 C.F.R. 103.3
  • Matter of Izummi
  • Matter of Katigbak
  • Matter of L-A-C-
  • Matter of O-R-E-
  • Matter of R-A-M-
  • USCIS Policy Manual F.5(B)(2)

Cases in adjacent profiles