The Petitioner, a supply chain manager, proposed to implement and disseminate a 'Predictive Demand and Inventory Intelligence Framework' (PDIIF) intended to improve inventory and demand planning across the U.S. CPG and automotive industries, claiming it would become a national reference model.

Prong 1 — national importancenot established · dispositive

“she has not established through independent evidence that her endeavor will impact the field of supply chain management more broadly”

“her initial filing lacked important details such as how this framework is an innovative or improved process compared to other standard methodologies currently used in the field”

“the addendum does not sufficiently detail the basis for the revenue and employment projections, and is not adequately supported by any independent evidence from BEA”

“the fact that a petitioner holds a position in an industry or sector that is the subject of national initiatives is not sufficient, in and of itself, to establish the national importance”

“they are largely letters from the Petitioner's colleagues who once again attest to successful execution of various projects during the course of her employment”

AAO decision text

How the evidence was treated

• degree · credited
• resume experience · credited
• recommendation letter · discounted

  “praised her work-related skills and abilities but did not address the details of her PDIIF initiative and its future impact”

  AAO decision text
• business plan · discounted

  “her initial filing lacked important details such as how this framework is an innovative or improved process compared to other standard methodologies”

  AAO decision text
• other · discounted

  “the opinion merely repeats and summarizes the information already presented in the record by the Petitioner”

  AAO decision text

Where this case turned

• Economic claims unsupported · p1 — job/revenue projections with no corroborating basis
• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• 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
• Letters not independent · p1 — letters come from employers and close collaborators, not independent experts

Notable

The AAO engaged in unusually granular scrutiny of a quantitative economic-impact addendum (GDP uplift, job creation figures using BEA RIMS II multipliers), faulting it for missing source tables and unexplained multiplier assumptions rather than rejecting the methodology outright. The AAO also clarified that USCIS's failure to expressly mention this addendum in its denial was not itself reversible error, citing circuit case law on agency reasoned-decision requirements.

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)
• Flores v. Garland

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