The Petitioner sought to work as an industrial engineering expert/consultant, variously described as managing industrial processes for unidentified companies, operating a combined industrial engineering and architecture business, creating standardized business manuals, and later conducting commercial negotiations, without a consistent description.

Prong 1 — national importancenot established · dispositive

“Based upon the evidence in the record, the Petitioner has not identified a specific or consistent proposed endeavor.”

“Therefore, we are unable to properly evaluate her endeavor under the first prong and conclude that the Petitioner did not demonstrate the endeavor's substantial merit and national importance.”

“But 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 does not offer any evidence that her skills differ from or improve upon those already available and in use in the United States.”

“However, 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.”

“The Petitioner has not provided evidence to support that her work as a business industrial engineering expert working for one or more employers would have substantially positive effects or would otherwise have broader implications beyond those employers.”

AAO decision text

How the evidence was treated

• business plan · discounted

  “we will therefore not consider the changes made to the Petitioner's proposed endeavor in reply to the Director's RFE and NOIR”

  AAO decision text
• degree · credited
• resume experience · discounted
• other · discounted

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

  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

Notable

AAO withdrew the Director's threshold EB-2 denial (advanced degree established) but still dismissed the appeal on prong 1, finding the Petitioner made material, shifting changes to her proposed endeavor across the initial filing, RFE response, NOIR response, and appeal (au pair/industrial engineer -> business owner combining engineering and architecture -> business manual creation -> commercial negotiations), invoking Matter of Izummi's bar on material changes and refusing to consider the later-described endeavors.

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
• 8 C.F.R. 204.5(k)(2)
• 8 C.F.R. 204.5(k)(3)(ii)
• Matter of Izummi
• Matter of L-A-C-
• Poursina v. USCIS

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• The Petitioner proposed to start a project management consultancy in the United States that would help small and mid-siz
• The Petitioner proposed to establish a legal consultancy in the United States focused on alternative dispute resolution