The Petitioner, an international development specialist working as global lead counsel for power, proposed to continue engaging in initiatives and projects in international development finance in the power sector, aiming to expand access to electricity and promote clean energy in emerging markets.

Prong 1 — national importancenot established · dispositive

“The absence of a clearly defined proposed endeavor prevents us from meaningfully assessing the endeavor's significance under the Dhanasar framework.”

“This shift introduced a new business model not previously described in the petition and significantly changed the nature of the proposed endeavor.”

“Merely working in an important field and the endeavor's alignment with government initiatives alone is insufficient for national importance.”

“the record does not establish how the Petitioner's specific proposed endeavor will have broader implications in her field, positively impact the U.S. economy, or generate direct and indirect jobs on a broad scale rising to the level of national importance.”

“Without sufficient evidence regarding the projected U.S. economic impact or job creation directly attributable to her future work, the record does not show that the benefits to the regional or national economy resulting from the Petitioner's endeavor would reach the level of "substantial positive economic effects" contemplated by Dhanasar.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the authors do not offer sufficient detail regarding the Petitioner's specific proposed endeavor and its national importance”

  AAO decision text
• resume experience · discounted

  “these experiences are misplaced in the context of the first Dhanasar prong”

  AAO decision text
• business plan · discounted

  “the Petitioner did not submit a business plan or implementation plans/timeline to support a plan to open a consulting firm”

  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
• 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

Notable

AAO found the Petitioner made an impermissible material change to her proposed endeavor by introducing a new consulting-firm business model in response to the RFE, and declined to consider that new endeavor, evaluating only the originally stated endeavor of continuing her existing employment-based work; this material-change finding was central to the p1 national-importance failure.

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. 103.2(b)(1)
• 8 C.F.R. 103.2(b)(12)
• 8 C.F.R. 103.2(b)(8)
• 8 C.F.R. 103.3
• 8 C.F.R. 204.5(k)(2)
• Matter of Izummi
• Matter of Katigbak
• Matter of L-A-C-

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