The Petitioner proposed to establish a startup company in California offering an AI-powered platform that creates digital representations of educators and content creators, enabling students to interact with those representations via voice or text 24/7. The stated goal was to improve the quality, accessibility, and affordability of education in the U.S. and worldwide.

Prong 1 — national importancenot established · dispositive

“The business plan provides arbitrary and unsubstantiated financial information that casts doubt on its veracity, undermining the reliability and sufficiency of both it and the remainder of the record.”

“neither the business plan nor the remainder of the record establish why the company anticipates such specific numbers of unit sales for the various product plans in any of the years of operations”

“the record does not indicate the significance of employing the stated number of workers in the given occupational categories in [redacted] California, in order to demonstrate significant potential to employ U.S. workers.”

“the Petitioner's conclusory statement on appeal that 'Advances in educational technology are, by their very nature, nationally significant' is unpersuasive.”

“the letters do not address the specific endeavor he proposes to undertake, and they bear minimal probative value for understanding evidence in the record”

AAO decision text

How the evidence was treated

• business plan · discounted

  “arbitrary and unsubstantiated financial information that casts doubt on its veracity, undermining the reliability and sufficiency of both it and the remainder of the record”

  AAO decision text
• recommendation letter · discounted

  “they do not address the specific endeavor he proposes to undertake, and they bear minimal probative value”

  AAO decision text
• other · discounted

  “it repeats information already in the record, it addresses generalized information attenuated from the specific endeavor the Petitioner proposes to undertake, and it references information outside the record”

  AAO decision text
• other · discounted

  “he does not substantiate his statements with objective evidence”

  AAO decision text

Where this case turned

• Business plan speculative · p1 — projections without a documented basis or steps
• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact
• Local, not national scope · p1 — impact confined to clients / a region

Notable

The AAO used the unreliability of the business plan's financial projections as a cascading evidentiary weapon under Matter of Ho, explicitly extending the doubt cast by the plan to undermine the professor of computer science's expert letter (because it relied on the plan) and the remainder of the record generally. The Petitioner cited an unspecified April 2025 executive order on appeal; the AAO took administrative notice that approximately three dozen executive orders were issued that month and rejected the argument for failure to identify the specific order. The AAO also explicitly noted the STEM policy manual provision (6 USCIS Policy Manual F.5(D)(4)) while rejecting the argument that being in a STEM field alone satisfies national importance.

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