NIW Bearings
remandedMAR082023_03B52032023-03-08 · appeal · Texas Service Center

This is an AAO appeal decision — a case denied once and appealed. It shows how the framework is applied; it is not the filing population.

The Petitioner, a dentist by training, initially proposed to conduct medical research developing a lighter, cheaper substitute for PMMA dermal filler, but later described (in RFE response) a plan to manage a cosmetic-surgery training and sales academy.

Field: dentistry / dental and aesthetic surgery research · Read the decision (uscis.gov)

EB-2 threshold — not met

AAO found the Petitioner did not establish U.S. equivalency of her foreign degree to an advanced degree and lacked evidence of progressive post-degree experience; remanded for Director to instead assess exceptional-ability eligibility.

Prong 1 — national importanceestablished

the RFE response presented a new set of facts regarding the work she will perform, which is material to eligibility for a national interest waiver
The information the Petitioner provided in the response to the Director's RFE did not clarify or provide more specificity to an initially described proposed endeavor

AAO decision text

How the evidence was treated

  • degree · discounted
    we conclude that the Petitioner has not met her burden to establish the U.S. equivalency of her foreign education
    AAO decision text
  • resume experience · discounted
    the record lacks evidence of the Petitioner's progressive, post-degree experience as a dentist, dental surgeon or researcher
    AAO decision text
  • business plan · discounted
    the RFE response presented a new set of facts regarding the work she will perform, which is material to eligibility
    AAO decision text

Where this case turned

  • Material change of endeavor · p1the endeavor described on appeal is not the one filed
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Notable

AAO independently consulted the AACRAO EDGE database to assess foreign-degree equivalency, finding the Petitioner's credentials equated only to a U.S. bachelor's degree; it withdrew the Director's EB-2 classification finding and remanded for the Director to instead evaluate exceptional-ability eligibility and, if met, to analyze all three Dhanasar prongs solely with respect to the Petitioner's original research-based endeavor, treating the later business-management proposal as an impermissible material change under Matter of Izummi.

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(g)(1)
  • 8 C.F.R. 204.5(k)(2)
  • 8 C.F.R. 204.5(k)(3)(iii)
  • Matter of Izummi
  • Poursina v. USCIS

What this case teaches

Analyst reading of the decision text.

Decisive factor

Petitioner impermissibly changed her proposed endeavor in the RFE response (from medical research to managing a training/sales academy), an improper material change; also failed to prove foreign degree equivalency for EB-2 classification.

Transferable lesson

Keep the proposed endeavor consistent from filing through RFE response—clarify, don't replace it—and independently substantiate foreign degree equivalency with formal evaluation evidence.

Endeavor framing

vague

National-importance theory

field_advancement · public_health

Evidence targeting

mixed

Cases in adjacent profiles