The petitioner proposed to work as CEO and Director of Analytics of her own consulting company, helping small and medium-sized insurance sector businesses implement digital transformation, data analytics, and automated tools to improve productivity and profitability.

Prong 1 — national importancenot established · dispositive

“the Petitioner must establish the national importance of her business rather than the importance of consulting services, data analytics, small businesses, and entrepreneurism.”

“the evidence does not sufficiently demonstrate that the Petitioner's specific undertaking stands to have an impact beyond the organizations and clients she would serve”

“Without evidence regarding any projected U.S. economic impact or job creation directly attributable to her future work operating a consulting business, the record does not show that benefits to the regional or national economy”

“The record does not indicate that the Petitioner's proposed endeavor involves HUBZone-certified companies or has any association to federal contracts.”

AAO decision text

How the evidence was treated

• other · discounted

  “The SBA program aims to award a certain percentage of federal contract dollars to HUBZone-certified companies... has not shown that the program confirms the national impact”

  AAO decision text
• other · credited
• resume experience · discounted

  “those relate to the second prong of the Dhanasar framework, which shifts the focus from the proposed endeavor to the foreign national”

  AAO decision text

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• 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
• Local, not national scope · p1 — impact confined to clients / a region

Notable

AAO reversed the Director's substantial-merit finding (crediting industry articles on big data/insurance importance) but still dismissed on national importance, illustrating the merit/importance split within prong 1. AAO also rejected a Buletini-based abuse-of-discretion argument regarding evidence consideration, and specifically addressed the SBA HUBZone certification argument as insufficient to show national importance.

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
• Buletini v. INS
• Flores v. Garland
• Matter of L-A-C-

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