The Petitioner, a pharmaceutical industrial production manager, proposed to plan, direct, and coordinate manufacturing activities for his employer, aiming to strengthen the pharmaceutical supply chain and mitigate drug shortages.

Prong 1 — national importancenot established · dispositive

“Merely working in an important field is insufficient to establish the national importance of the proposed endeavor.”

“he does not elaborate how his proposed endeavor specifically will address this issue and have such broader impact in the industry that it would rise to the level of national importance.”

“the evidence indicates that the facility will be located in Brazil, not the United States.”

“Without adequate evidence demonstrating any specific U.S. economic impact, job creation, or other significant economic activity directly attributable to his future work, the Petitioner's claims... is unpersuasive.”

“We also note that shortages of qualified workers are directly addressed by the U.S. Department of Labor through the labor certification process.”

“the opinion letter does not provide sufficient corroborating evidence to support the endeavor's alleged broader impacts to the industry or nation.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the opinion letter does not provide sufficient corroborating evidence to support the endeavor's alleged broader impacts to the industry or nation.”

  AAO decision text
• resume experience · discounted

  “the Petitioner's knowledge, skills, education, and experience are considerations under Dhanasar's second prong.”

  AAO decision text
• other · discounted

  “the articles and reports provide only general background information on these industries and fields and do not specifically relate to... the Petitioner's proposed endeavor.”

  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
• Local, not national scope · p1 — impact confined to clients / a region
• Occupational shortage argument rejected · p1 — argues a labor shortage — the labor-certification question, not Dhanasar

Notable

The AAO explicitly distinguished economic-impact evidence tied to a foreign (Brazilian) facility from U.S. national importance, and rejected the Petitioner's argument that lack of second-prong objection by the Director conceded that prong, citing Bagamasbad's doctrine of declining to reach unnecessary issues.

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
• Flores v. Garland
• Matter of L-A-C-

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