The Petitioner proposed to establish and lead a financial services consulting business in Florida providing advisory services to small and medium-sized enterprises and financial literacy education to immigrant communities.

Prong 1 — national importancenot established · dispositive

“The Director found that the Petitioner did not demonstrate her proposed endeavor would extend beyond her business and clients to have a potential prospective impact on her field more broadly.”

“Any basic economic activity has the potential to positively impact the economy; however, the Petitioner has not offered a sufficiently direct connection between her proposed endeavor's activities to provide financial advisor consulting to businesses and immigrant communities that would potentially have a demonstratable substantial economic benefit to Florida or the nation.”

“Working in or establishing a business in an important field is insufficient on its own to establish the national importance of the proposed endeavor.”

“Although the Petitioner indicated that her consulting work will create economic benefits for her business' clients and employ approximately eight to ten employees, she has not provided objective and corroborating details as to how such projections are created, aside from generalized claims and statements.”

“The Petitioner has not sufficiently established the national importance of her proposed endeavor as required by the first prong of the Dhanasar precedent decision”

AAO decision text

How the evidence was treated

• business plan · discounted

  “she has not provided objective and corroborating details as to how such projections are created, aside from generalized claims and statements”

  AAO decision text
• recommendation letter · discounted

  “determined overall that the quality of the evidence lacked probative value in supporting her claim that the proposed endeavor is of national importance”

  AAO decision text
• other · discounted

  “their overall significance does not establish the national importance of the Petitioner's proposed endeavor in particular”

  AAO decision text
• degree · credited

Where this case turned

• Business plan speculative · p1 — projections without a documented basis or steps
• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• 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

Petitioner argued the Director committed abuse of discretion by not individually analyzing each of ~29 pieces of submitted evidence, citing Buletini v. INS; AAO rejected this, holding reasoned consideration does not require addressing every document, citing multiple circuit court cases (Guaman-Loja, Martinez, Kazemzadeh, Casalena). AAO also rejected Petitioner's argument that Director improperly emphasized 'geographical scope' as a novel criterion beyond Dhanasar.

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
• INA 203(b)(2)
• Matter of E-M-
• Matter of L-A-C-

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