The Petitioner, an entomology professor, proposed to conduct research on insecticide resistance mechanisms in German cockroaches, in collaboration with U.S. university programs, to help develop improved pest control solutions.

Prong 1 — national importancenot established · dispositive

“we agree that the Petitioner has not established the national importance of the proposed endeavor and we will dismiss the appeal on that basis.”

“In the Petitioner's initial statement, he did not provide a specific a proposed endeavor.”

“The letter from Dr. S.O.R., ... primarily provides general, conclusory statements about the proposed endeavor.”

“The importance of an industry or field is not sufficient to meet the national importance requirement under the Dhanasar framework.”

“This evidence provides background information, but it does not discuss the Petitioner's specific proposed endeavor or help demonstrate interest in this specific topic or its potential prospective impact.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “The letters mainly discuss the writers' knowledge of the Petitioner's prior projects and then restate the Petitioner's broad assertions.”

  AAO decision text
• other · discounted

  “This evidence provides background information, but it does not discuss the Petitioner's specific proposed endeavor.”

  AAO decision text
• other · ignored

  “Because the Petitioner was previously put on notice and given a reasonable opportunity to provide this evidence, we will not consider it for the first time on appeal.”

  AAO decision text

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• 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
• Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact

Notable

AAO declined to consider evidence submitted for the first time on appeal, citing Matter of Furtado (BIA 2024) and 8 C.F.R. 103.2(b)(11), applying a BIA precedent to an AAO NIW appeal. AAO explicitly reserved opinion on prongs 2 and 3, citing INS v. Bagamasbad to justify not reaching advisory findings. Decision draws an extended comparison to the facts of Dhanasar itself to illustrate the required level of specificity/impact.

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. 103.3
• 8 C.F.R. 103.5
• Flores v. Garland
• Matter of E-M-

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