The Petitioner, an attorney, proposed to work as a legal consultant in the U.S. helping multinational U.S. companies expand into Brazil and Brazilian companies expand into the U.S., through a company she and her spouse established in Florida.

Prong 1 — national importancenot established · dispositive

“she has not explained how this proposed work would have the broader implications for international trade that she claims, beyond the scope of the clients she would serve”

“It is therefore insufficient to show a significant potential to employ workers.”

“the business plan does not sufficiently show that the activities o f would potentially have significant positive economic effects”

“the Petitioner has not shown that her specific proposed endeavor will have the broader implications in this area that are required to establish its national importance”

AAO decision text

How the evidence was treated

• business plan · discounted

  “the business plan does not sufficiently show that the activities o f would potentially have significant positive economic effects”

  AAO decision text
• recommendation letter · discounted

  “Neither of these letters support the national importance of the Petitioner's proposed endeavor.”

  AAO decision text
• other · ignored

  “the AAO will not accept evidence offered for the first time on appeal”

  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

Notable

The Director's own decision contained internally contradictory statements (asserting both that Petitioner had 'no endeavor' and that she had submitted a detailed description and documentation of substantial merit); AAO corrected this but still dismissed on national importance grounds. AAO also declined to consider a new letter submitted for the first time on appeal under Matter of Soriano/Obaigbena, and noted inconsistencies in the business plan (e.g., Houston rent figures for a Florida-based business) citing Matter of Ho regarding resolving discrepancies.

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)
• Flores v. Garland
• Matter of Ho
• Matter of L-A-C-

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