The Petitioner, a systems engineer, proposed to apply her professional experience to design and develop novel software platforms that would facilitate the delivery of virtual clinical mental health services in the United States, operated through her own company.

Prong 1 — national importancenot established · dispositive

“the record lacks specific and persuasive details regarding the proposed endeavor and its impact.”

“the Petitioner has not shown her endeavor stands to sufficiently extend beyond her company or its clients to impact the mental health field or the U.S. economy broadly”

“the record does not provide objective and corroborating details as to how such projections are created, aside from generalized claims and statements.”

“in determining national importance, the relevant question is not the importance of the field, industry, or professional in which the individual will work”

AAO decision text

How the evidence was treated

• business plan · discounted

  “the record does not provide objective and corroborating details as to how such projections are created, aside from generalized claims and statements.”

  AAO decision text
• recommendation letter · discounted

  “generally address the importance of the mental health field but do not discuss the proposed endeavor with persuasive and corroborating details.”

  AAO decision text
• other · discounted

  “None of the articles and reports specifically mention the Petitioner's endeavor or discuss the government's interest in promoting the use of the Petitioner's innovation or solutions.”

  AAO decision text
• resume experience · credited
• degree · credited

Where this case turned

• 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
• 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

Notable

The Director had found the Petitioner met Dhanasar's second prong but failed the third; the AAO expressly declined to reach prongs two and three after finding prong one dispositive, yet the order states the decision rests on 'each considered as an independent and alternate basis,' an apparent inconsistency given only prong one was actually analyzed. A footnote also discusses two advisory opinion letters that were discounted as repetitive of other submissions and lacking claimed expertise in the specific technology.

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
• Flores v. Garland
• INA 203(b)(2)
• Matter of E-M-
• Matter of L-A-C-

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