The Petitioner, a programmer analyst at a jewelry business, proposed to design, develop, and deploy AI-based image-recognition software to automate quality inspection, defect detection, and authentication in jewelry manufacturing, initially for his employer with plans to later market it to other jewelry manufacturers.

Prong 1 — national importancenot established · dispositive

“the plans are brief and vague, lacking detailed information and evidence corroborating his claims of the project's broad impacts.”

“USCIS determined that the Petitioner did not demonstrate his proposed endeavor would extend beyond his employer, ... and its clients”

“merely using artificial intelligence technologies in the jewelry manufacturing field or working in a growing field with a shortage of workers is insufficient”

“The Petitioner, however, has not provided corroborating independent and objective evidence to support his claims that his project stands to provide substantial economic benefits”

“the importance of an industry or field, such as artificial intelligence and its use for jewelry manufacturing, is not sufficient to meet the national importance requirement”

AAO decision text

How the evidence was treated

• business plan · discounted

  “the plans are brief and vague, lacking detailed information and evidence corroborating his claims of the project's broad impacts.”

  AAO decision text
• recommendation letter · discounted

  “speaks in general terms about interest in the project and the jeweler's admiration ... but does not explain the specifics”

  AAO decision text
• motion resubmission · ignored

  “we will not consider this new evidence for the first time on appeal, as it was not presented to USCIS”

  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
• Occupational shortage argument rejected · p1 — argues a labor shortage — the labor-certification question, not Dhanasar

Notable

AAO disagreed with USCIS's finding that the RFE-response evidence (business plan, letter of intent, collaboration agreement) constituted a material change, treating it instead as permissible clarification, but nonetheless dismissed on prong 1 national importance; AAO refused to consider a new expert opinion letter submitted for the first time on appeal, citing Matter of Soriano.

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
• 8 C.F.R. 103.5
• Flores v. Garland
• Matter of E-M-
• Matter of Izummi
• Matter of L-A-C-
• USCIS Policy Manual F.5(D)(2)

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