The petitioner sought to conduct research on recycled materials in asphalt pavement, including validating and refining the Viscoelastic Continuum Damage (VECD) model for indirect tension testing applications.

Prong 1 — national importancenot established · dispositive

“The Petitioner's work in a STEM field alone is insufficient to establish the national importance of his proposed endeavor.”

“However, S-D-D-, J-S-, A-B­ ' R-K-, and C-W- do not discuss the impact of the Petitioner's work on the VECD model as he described in his RFE response detailing his proposed endeavor.”

“These materials do not address the Petitioner's proposed endeavor.”

“it does not establish that his proposed endeavor has broader implications in his field commensurate with national importance”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “do not discuss the impact of the Petitioner's work on the VECD model as he described in his RFE response”

  AAO decision text
• citations publications · discounted

  “it does not establish that his proposed endeavor has broader implications in his field commensurate with national importance”

  AAO decision text
• other · discounted

  “These materials do not address the Petitioner's proposed endeavor.”

  AAO decision text

Where this case turned

• Citations insufficient · p1 — citation counts without qualitative account of impact
• 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
• Letters not independent · p1 — letters come from employers and close collaborators, not independent experts

Notable

AAO agreed the Director erred procedurally by failing to fully assess national importance under all Dhanasar factors, but nonetheless conducted its own de novo analysis and reached the same negative conclusion, illustrating that procedural criticism of the Director does not necessarily change the outcome.

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
• Matter of L-A-C-
• USCIS Policy Manual F.5(D)(2)

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