The Petitioner proposed to design, implement, and optimize financial workflow processes for small and medium-sized enterprises using API-based technologies, aiming to improve cash flow management and strategic planning, and to share her methodologies at industry conferences.

Prong 1 — national importancenot established · dispositive

“USCIS specifically discussed the Petitioner's model plan and determined that the Petitioner relies on arguments related to the importance of the field rather than the proposed endeavor's national importance.”

“It is insufficient to claim an endeavor has national importance or would create a broad impact without providing evidence to substantiate such claims.”

“she did not provide a business plan, or any other plans or projections explaining the expected scope of her intended activities”

“his opinion is largely conclusory and does not adequately explain how the Petitioner's work would produce such nationally important impacts”

“the evidence does not establish the proposed endeavor's national importance because they only highlight that the endeavor's impact is to the individual client or companies that hire the Petitioner”

AAO decision text

How the evidence was treated

• degree · discounted

  “The regulation ... does not contemplate a combination of a degree that is not equivalent to a U.S. degree with a diploma that also is not equivalent to a U.S. degree”

  AAO decision text
• recommendation letter · discounted

  “his opinion is largely conclusory and does not adequately explain how the Petitioner's work would produce such nationally important impacts”

  AAO decision text
• business plan · discounted

  “she did not provide a business plan, or any other plans or projections explaining the expected scope of her intended activities”

  AAO decision text
• other · discounted

  “the evidence does not establish the proposed endeavor's national importance because they only highlight that the endeavor's impact is to the individual client”

  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
• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• 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

Notable

The AAO sua sponte withdrew USCIS's favorable finding on threshold EB-2 eligibility, holding that the Petitioner's combination of two non-equivalent foreign credentials did not satisfy the advanced degree regulation, yet proceeded to analyze and dismiss on Dhanasar prong 1 grounds as well, reserving prongs 2 and 3 (noting USCIS had found prong 2 met without analysis). The Petitioner unsuccessfully cited a non-precedential district court case (Buletini v. INS) to argue USCIS failed to consider all evidence.

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. 204.5(k)(2)
• Buletini v. INS
• Flores v. Garland
• INA 203(b)(2)
• Matter of Caron Int'l
• Matter of D-R-
• Matter of L-A-C-

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