The Petitioner sought to operate her own company in the U.S. providing audiovisual content planning, production, and marketing coaching services to minority-owned small and medium-sized businesses, particularly those in IRS-designated opportunity zones.

Prong 1 — national importancenot established · dispositive

“However, while the Petitioner has established that the proposed endeavor has substantial merit, the record does not show it has national importance.”

“the Petitioner has not shown the broader implications of her proposed endeavor, however admirable, rise to the level of national importance”

“unsubstantiated claims are not sufficient to establish national importance”

“when considering the national importance of a proposed endeavor, the industry or customer base a petitioner will serve alone is not sufficient”

“the business plan provides little explanation and objective basis of these projections”

“Even if the endeavor's revenue and job creation projections were sufficiently corroborated, they do not establish that the endeavor would operate on a scale rising to the level of national importance”

“Generalized conclusory statements that do not identify a specific impact in the field have little probative value”

AAO decision text

How the evidence was treated

• business plan · discounted

  “the business plan provides little explanation and objective basis of these projections”

  AAO decision text
• recommendation letter · discounted

  “do not analyze the Petitioner's specific proposed endeavor or offer evidence of its impact, beyond commenting on her expertise”

  AAO decision text
• other · discounted

  “The articles do not discuss the Petitioner's work or her proposed endeavor.”

  AAO decision text
• awards · ignored

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 abused discretion by imposing 'novel requirements' (e.g., baseline employee numbers) and relied on Buletini v. INS for totality-of-evidence review; AAO rejected these arguments and cited multiple circuit court decisions (Ren, Osuchukwu) affirming agencies need not address every piece of evidence individually. AAO also noted Petitioner had not established a physical business location within an IRS opportunity zone, undermining that argument.

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
• 8 C.F.R. 204.5(k)(2)
• Buletini v. INS
• Flores v. Garland
• Matter of L-A-C-

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