The Petitioner sought to own and serve as COO of a Florida LLC providing corporate financial management and consulting services (balance sheet analysis, bank reconciliation, financial planning, and an online 'knowledge factory') to entrepreneurs and businesses.

Prong 1 — national importancenot established · dispositive

“the Petitioner has not established that her proposed endeavor's impact will extend beyond her LLC's clients and customers to be considered of national importance”

“the Petitioner's emphasis on these fields is misplaced because as we explained in Dhanasar, even if a petitioner is engaged in important activities”

“the EPI multiplier formula's data is not sufficiently tailored to the Petitioner's proposed endeavor to persuasively support the economic impacts noted above”

“absent a specific plan that demonstrates how she intends to generate revenue, it is not evident that the Petitioner's LLC will generate revenue and create jobs”

AAO decision text

How the evidence was treated

• business plan · discounted

  “absent a specific plan that demonstrates how she intends to generate revenue, it is not evident that the Petitioner's LLC will generate revenue and create jobs”

  AAO decision text
• recommendation letter · ignored
• resume experience · discounted

  “her professional experiences do not focus on the merit and importance of the proposed endeavor”

  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
• Field importance conflated with endeavor · p1 — argues the field matters, not the specific endeavor
• Local, not national scope · p1 — impact confined to clients / a region

Notable

AAO specifically rejected the Petitioner's use of the Economic Policy Institute employment-multiplier formula as too broad/untailored to support job-creation claims, and found environmental/social 'Triple Bottom Line' sustainability initiatives insufficient to show national importance despite being 'commendable.'

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
• USCIS Policy Manual F.5(D)(1)

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