The Petitioner, a systems engineer with over two decades of experience, proposed to help U.S.-based small and medium-sized companies expand into foreign markets by developing strategies to overcome barriers such as limited resources and local regulatory complexity.

Prong 1 — national importancenot established · dispositive

“Much of those previous claims are comprised of vague generalities of business improvements and opportunities.”

“he has not shown that his endeavor will have substantial positive economic effects or impacts”

“SCOPS noted a lack of information and probative supporting evidence relating to how his services and company will expand to multiple cities, how he will achieve the estimates for client and revenue growth year-over-year”

“it is essential to differentiate between localized impacts and those of national significance. Merely demonstrating secondary effects within a narrow area does not inherently satisfy the stringent threshold for national importance.”

“the Petitioner did not identify any specific letter or explain how any letter adequately supports his claims”

AAO decision text

How the evidence was treated

• business plan · discounted

  “a lack of information and probative supporting evidence relating to how his services and company will expand to multiple cities”

  AAO decision text
• recommendation letter · discounted

  “the Petitioner did not identify any specific letter or explain how any letter adequately supports his claims”

  AAO decision text
• media · discounted

  “how any of the media coverage applied to his proposed endeavor instead of generally applying to small startup businesses”

  AAO decision text
• motion resubmission · discounted

  “he discusses claims and evidence in a similar manner that he already did before SCOPS”

  AAO decision text
• other · discounted

  “any foreign language document containing deficiencies in translation or based on a blanket certification of translation is not probative 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
• Endeavor too vague · p1 — described as a job role, not a defined undertaking
• 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 decision extensively applies a circuit-court 'ignored evidence' standard (Cruz v. Bondi, Gov't of Guam v. Guerrero, etc.) requiring the Petitioner to show clear, affirmative proof that USCIS did not review evidence, and separately faults the Petitioner's foreign-language documents for lacking document-specific translation certifications. The AAO explicitly states each of its stated grounds is an independent and alternative basis for dismissal.

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)(3)
• Flores v. Garland
• INA 203(b)(2)
• INA 291
• Matter of E-M-

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