The Petitioner, a food scientist, proposed to apply biotechnology, bioengineering, and nanotechnology to food production to improve food quality, safety, and nutrition, including specific research on lipid-soluble vitamin interactions in animal products and enzymatic deamidation of whey proteins, while pursuing an assistant professor position in the U.S.

Prong 1 — national importanceestablished

“we agree with USCIS that the Petitioner meets the first prong of the Dhanasar framework.”

AAO decision text

Prong 2 — well positionednot established · dispositive

“the Petitioner's advanced degree in a STEM field is not a sufficient basis to determine that she is well-positioned to advance her proposed endeavor.”

“she has not established how this level of citation is indicative of a record of success in her field.”

“citation frequency, which is quantitative in nature, does not reveal the reasons for the citations, which involves a qualitative analysis.”

“the authors of these letters do not provide sufficient detail about how the Petitioner's work has affected the field or industry”

“we conclude that the fact that she does not currently have such a position weighs against her claim that she has either a specific model or plan for future activities”

“the record does not show, for example, that she has co-authored any published work stemming from her research activities”

“the Petitioner did not offer evidence showing that she has received funding for her research proposals or future projects.”

AAO decision text

How the evidence was treated

• degree · credited
• citations publications · discounted

  “citation frequency, which is quantitative in nature, does not reveal the reasons for the citations, which involves a qualitative analysis.”

  AAO decision text
• recommendation letter · discounted

  “the letters lack specificity and do not adequately address how the Petitioner's work has been adopted by others, influenced the field, generated positive discourse”

  AAO decision text
• resume experience · discounted

  “the record does not contain documents detailing her employment history”

  AAO decision text
• business plan · discounted

  “the fact that she does not currently have such a position weighs against her claim that she has either a specific model or plan for future activities”

  AAO decision text

Where this case turned

• Business plan speculative · p2 — projections without a documented basis or steps
• Citations insufficient · p2 — citation counts without qualitative account of impact
• Education alone insufficient · p2 — degrees offered as positioning — credentials are not a track record
• Funding absent · p2 — no documented funding or resources behind the plan
• Letters conclusory · p2 — letters praise skills in general terms without tracing specific impact
• No progress evidence · p2 — no documented movement toward the endeavor since filing
• Record of success insufficient · p2 — a claimed track record the documents do not establish

Notable

The AAO engages in an unusually granular statistical critique of the Petitioner's citation evidence, rejecting her Clarivate Analytics percentile data because it relied on 'Environment/Ecology' baseline rather than 'Agricultural Sciences,' and rejecting her OpenAlex percentile data for relying on post-filing (2024) citation counts and unexplained methodology. The AAO also distinguishes the petitioner's case from Matter of Dhanasar itself, noting Dr. Dhanasar's eligibility rested on sustained government funding and grant leadership rather than citation counts.

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. 103.2(b)(12)
• 8 C.F.R. 103.3
• 8 C.F.R. 103.3(c)
• 8 C.F.R. 204.5(k)(2)
• Flores v. Garland
• Matter of E-M-
• Matter of Katigbak

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