NIW Bearings
remandedMAY162024_04B52032024-05-16 · 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 civil engineer, sought to open and direct the operations of an information technology and gamification consulting firm in Florida.

Field: IT and gamification consulting (petitioner trained as civil engineer) · Read the decision (uscis.gov)

EB-2 threshold — addressed

Director found petitioner did not qualify as exceptional ability despite meeting 4 of 6 evidentiary criteria; AAO withdrew this finding because the Director's final merits determination failed to analyze the totality of the evidence and did not explain the reasons for denial.

Prong 1 — national importanceestablished

Prong 2 — well positionedestablished

Prong 3 — balance of factorsestablished

How the evidence was treated

  • business plan · ignored
  • recommendation letter · ignored
  • resume experience · ignored
  • certification membership · credited
  • degree · credited

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Notable

This is a procedural remand rather than a merits determination: the AAO did not affirm any prong failure but instead withdrew the Director's decision for failing to analyze the totality of the evidence and adequately explain the reasons for denial under 8 C.F.R. 103.3(a)(1)(i). The AAO specifically noted the Director erroneously conflated Dhanasar prong 2 factors (record of success, progress, customer interest) into the prong 1 national importance analysis, and mistakenly described the endeavor as 'founding and leading a company in accounting services' when the actual endeavor was an IT and gamification consulting company.

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. 204.5(k)(2)
  • 8 C.F.R. 204.5(k)(3)(ii)
  • Flores v. Garland

What this case teaches

Analyst reading of the decision text.

Decisive factor

Director's decision was conclusory, failed to consider totality of evidence, conflated prong-2 factors into prong-1 analysis, and mischaracterized the endeavor (calling it 'accounting services'), requiring remand for proper reasoned analysis.

Transferable lesson

Ensure adjudicator's denial explicitly engages with all submitted evidence and correctly identifies the endeavor; procedural deficiencies in agency reasoning can win a remand even without merits ruling.

Endeavor framing

moderate

National-importance theory

stem_positive_factor · economic_job_creation · economic_growth_generic

Evidence targeting

mixed

Cases in adjacent profiles