The Petitioner, a mathematics/electrical-engineering researcher, proposed to continue research on manifold and graph neural networks and multi-armed bandit theory to support applications such as wireless communications, chip design, and medical imaging, moving from a graduate research assistantship into a post-doctoral position and later an assistant professorship.

Prong 1 — national importancenot established · dispositive

“The Petitioner did not clearly define a proposed endeavor at the time of filing.”

“The evidence in the record does not establish that, at the time of filing, the Petitioner possessed a specific endeavor that she proposed to undertake”

“the importance of an industry or field is not sufficient to meet the national importance requirement under the Dhanasar framework.”

“she has not shown that the funding was provided specifically for her work.”

“her former advisors and colleagues, however, do not identify or address her specific proposed endeavor.”

“Her research project descriptions ... are brief summaries, without specific details or evidence supporting her claims of their impacts.”

AAO decision text

How the evidence was treated

• degree · credited
• recommendation letter · discounted

  “do not identify or address her specific proposed endeavor”

  AAO decision text
• funding · discounted

  “she has not shown that the funding was provided specifically for her work”

  AAO decision text
• citations publications · discounted

  “such previous work mainly relates to whether she is well-positioned to advance her endeavor under Dhanasar's second prong”

  AAO decision text
• business plan · discounted

  “are brief summaries, without specific details or evidence supporting her claims of their impacts”

  AAO decision text

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
• Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact
• Material change of endeavor · p1 — the endeavor described on appeal is not the one filed

Notable

The AAO granted part of the motion to reopen on the threshold advanced-degree issue (new academic record evidence cured the prior defect) but still dismissed the overall motion because eligibility for the NIW was not shown. It invoked the Katigbak/Izummi 'material change' doctrine to reject reliance on evidence describing a different endeavor tied to employment obtained after filing, then went on, in the alternative, to find national importance unproven even if that later-described endeavor were considered. Second and third Dhanasar prongs were expressly reserved.

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. 103.5
• Flores v. Garland
• Matter of Coelho
• Matter of Izummi
• Matter of Katigbak
• USCIS Policy Manual F.5(D)(2)

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