NIW Bearings
remandedMAR242022_01B52032022-03-24 · 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 mechanical engineer, initially proposed to continue working in mechanical engineering with multi-national companies, but later described (in RFE response) an additional entrepreneurial endeavor operating a holding company selling construction-related project design services and home goods.

Field: mechanical engineering · Read the decision (uscis.gov)

EB-2 threshold — not met

AAO withdrew the Director's finding that Petitioner qualified as an advanced degree professional, noting the submitted 'Record of Employment' listing generic managerial responsibilities may not sufficiently establish five years of progressive post-baccalaureate experience in mechanical engineering; remanded for the Director to determine anew, and if not met, to consider exceptional ability.

Prong 1 — national importancenot established

we withdraw the Director's conclusions that the Petitioner has established that 1) he is an advanced degree professional and 2) his proposed endeavor meets prong one under the Dhanasar analysis.
The Petitioner, however, must establish eligibility at the time of filing.
A petitioner may not make material changes to a petition in an effort to make a deficient petition conform to USCIS requirements.

AAO decision text

How the evidence was treated

  • resume experience · discounted
  • business plan · discounted
    A petitioner may not make material changes to a petition in an effort to make a deficient petition conform to USCIS requirements.
    AAO decision text

Where this case turned

  • Business plan speculative · p1projections without a documented basis or steps
  • Endeavor too vague · p1described as a job role, not a defined undertaking
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Notable

AAO remands rather than dismisses or sustains: it withdraws the Director's favorable findings on both threshold EB-2 eligibility (advanced degree professional) and Dhanasar prong one, flagging a possible material change in the proposed endeavor (mechanical engineer vs. added entrepreneur/business-plan endeavor introduced in RFE response) and directing the Director to resolve both issues anew, including consideration of exceptional-ability classification if advanced-degree status is not established.

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)(12)
  • 8 C.F.R. 204.5(k)(2)
  • 8 C.F.R. 204.5(k)(3)(ii)
  • INA 203(b)(2)
  • Matter of Izummi
  • Matter of Katigbak
  • Poursina v. USCIS

What this case teaches

Analyst reading of the decision text.

Decisive factor

Unresolved threshold issues: whether Petitioner qualifies as advanced-degree professional/exceptional ability, and whether RFE response materially changed the proposed endeavor, precluded prong-one analysis.

Transferable lesson

Fix and consistently document the underlying EB-2 classification and specific endeavor at filing; do not introduce a materially different endeavor in RFE response.

Endeavor framing

vague

National-importance theory

other

Evidence targeting

person_focused

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