The Petitioner, a public relations specialist, proposed to work for or consult with U.S. and foreign businesses on reputation management and communications strategy, claiming this would generate foreign investment and economic benefits.

Prong 1 — national importancenot established · dispositive

“the relevant question is not the importance of the industry, sector, or profession in which the individual will work; instead, we focus on "the specific endeavor that the foreign national proposes to undertake."”

“the record does not show that any benefits to the U.S. regional or national economy resulting from his public relations services would reach the level of "substantial positive economic effects"”

“Although the proposed endeavor may benefit the client companies and individuals that engage the Petitioner's services, the record does not sufficiently show that such benefits...would rise to the level of national importance.”

“much of the content of the expert opinion letter lacked relevance and probative value with respect to the national importance of the Petitioner's initial proposed endeavor.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the author does not indicate how the Petitioner's Professional Plan & Statement supports a determination that the initial proposed endeavor has significant potential to employ U.S. workers”

  AAO decision text
• resume experience · discounted

  “the Petitioner's expertise acquired through his academic and professional career primarily relates to the second prong of the Dhanasar framework”

  AAO decision text
• media · discounted

  “the Petitioner must still demonstrate the potential prospective impact of his specific, proposed endeavor...rather than the importance of the occupation or the industry or field”

  AAO decision text
• motion resubmission · discounted

  “we will not consider the Petitioner's materially changed proposed endeavor of applied researcher”

  AAO decision text

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• 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

Notable

The Petitioner materially changed his proposed endeavor between filing (PR specialist/consultant) and the RFE response (applied researcher in crisis/risk communication funded by NOAA), even acknowledging on the Form I-290B that his plans had changed. Citing Katigbak and Izummi, the AAO refused to consider the new endeavor and evaluated only the endeavor as stated at filing, ultimately finding it lacked national importance and dismissing the appeal on prong 1 alone without reaching prongs 2 or 3.

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
• Matter of Caron Int'l
• Matter of D-R-
• Matter of Izummi
• Matter of Katigbak
• Matter of L-A-C-

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