The Petitioner, a business administrator, proposed to continue working with U.S. companies on business development and expansion, using a self-developed methodology he called the 'Triad of Value' (also referred to inconsistently as 'Triad of Valor').

Prong 1 — national importancenot established · dispositive

“The Petitioner's argument spotlights a fundamental misunderstanding of the first prong of the Dhanasar framework.”

“The Petitioner's meandering explanation appears to be technical jargon without any cognizable substance with which the national importance of the 'Triad of Value' can be evaluated.”

“The Petitioner has not established that their proposed endeavor is of national importance.”

“But the impact of the Petitioner's services on the small businesses and public health on a larger basis than just the subset of those groups taking advantage of the Petitioner's services does not rise to a level of national importance.”

AAO decision text

Prong 2 — well positionednot established

“But simply having education, skills, and/or knowledge in isolation do not place a petitioner in a position to advance their proposed endeavor.”

“The record simply does not reflect any progress to achieving the proposed endeavor.”

“And the recommendation letters the Petitioner submitted are not material, relevant, or probative evidence in the record of interest or support in the endeavor the Petitioner proposed in their petition.”

“It did not demonstrate how they planned to engage with the target audience or anything else which constituted the development of a model for future activities.”

AAO decision text

How the evidence was treated

• resume experience · discounted

  “The Petitioner's employment verification letters did not reflect how national importance was implicated by the Petitioner's proposed endeavor because the letters focused on the Petitioner's past work.”

  AAO decision text
• certification membership · discounted

  “The certificates earned by the Petitioner relate to them as an individual and their own personal development of their core skills.”

  AAO decision text
• business plan · discounted

  “The Petitioner's meandering explanation appears to be technical jargon without any cognizable substance with which the national importance of the 'Triad of Value' can be evaluated.”

  AAO decision text
• recommendation letter · discounted

  “The recommendation letters the Petitioner submitted are not material, relevant, or probative evidence in the record of interest or support in the endeavor the Petitioner proposed.”

  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
• Business plan speculative · p2 — projections without a documented basis or steps
• Education alone insufficient · p2 — degrees offered as positioning — credentials are not a track record
• Letters not independent · p2 — letters come from employers and close collaborators, not independent experts
• No progress evidence · p2 — no documented movement toward the endeavor since filing
• Record of success insufficient · p2 — a claimed track record the documents do not establish
• Derivative of Prong 1/2 failure · p3 — prong three fails only because prongs one or two did — no independent ground

Notable

AAO withdrew the Director's favorable finding on prong 2 even though it did not need to, since prong 1 was already dispositive; also noted a curious discrepancy where the Petitioner's 'Professional Plan' inconsistently referred to a 'Triad of Value' vs. 'Triad of Valor,' which the AAO flagged as possibly a post-RFE branding exercise rather than a typo.

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
• INA 203(b)(2)
• Matter of L-A-C-
• Matter of Y-B-
• Poursina v. USCIS

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• The Petitioner proposed to establish a legal consultancy in the United States focused on alternative dispute resolution