The Petitioner, a financial director and part-owner of a used car dealership in Alaska, initially proposed to continue working as the dealership's financial director, later attempting to shift her endeavor to founding a national SME financial-consulting platform.

Prong 1 — national importancenot established · dispositive

“the Petitioner's statements and evidence in the record do not offer a consistent, specific proposed endeavor and contain material changes.”

“the Petitioner made an impermissible material change to her proposed endeavor when USCIS asked for more details about her proposed endeavor in the RFE.”

“Generalized conclusory statements that do not identify a specific impact in the field have little probative value.”

“the record does not offer any sufficient, specific information and evidence regarding her proposed endeavor or its prospective impact rising to the level of national importance.”

“the Petitioner has not established that her endeavor has significant potential to employ U.S. workers or otherwise offers substantial positive economic effects for our nation.”

“it is the substantial merit of the specific endeavor that must be established, not the merits of an entire field or industry.”

“the Petitioner has not provided evidence to support that her work as a financial director working for her car dealership or other companies would have substantially positive effects or would otherwise have broader implications beyond those employers.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “do not establish the endeavor's national importance, not only because they contain similar language or structure”

  AAO decision text
• business plan · discounted

  “we will not consider the changes made to the Petitioner's proposed endeavor”

  AAO decision text
• citations publications · discounted

  “the expert opinion letter from Professor P-r-M- lacks probative value as it was introduced after Petitioner materially changed her proposed endeavor”

  AAO decision text
• degree · credited

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• 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
• Material change of endeavor · p1 — the endeavor described on appeal is not the one filed

Notable

The AAO applied the Matter of Izummi 'material change' doctrine—typically used for petition-eligibility changes—to reject the Petitioner's RFE-stage reformulation of her NIW endeavor, then evaluated only the vague original endeavor (financial director for her own dealership) and found it lacked national importance, declining to reach prongs two and three.

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
• Flores v. Garland
• Matter of E-M-
• Matter of Izummi

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