The petitioner, a biomedical engineering researcher pursuing a doctorate, proposed to continue research using AI/machine-learning models to analyze neuroimaging data in order to better understand brain disorders such as Alzheimer's, ADHD, and depression and to develop diagnostic biomarkers and treatment tools.

Prong 1 — national importanceestablished

Prong 2 — well positionednot established · dispositive

“he has not demonstrated a record of success in similar efforts with respect to his research”

“the authors of these letters do not provide sufficient detail explaining the significance of the Petitioner's past research”

“The Petitioner has therefore not shown that his work constitutes a record of success beyond having been cited by others in their published works”

“the Petitioner's personal statements and evidence do not show that his current work relates to his proposed endeavor”

“he has not provided evidence that he himself previously received funding for his research or has secured funding to continue pursuing his specific proposed endeavor”

“it is not a sufficient basis to determine that he is well positioned to advance his proposed endeavor”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “do not provide sufficient detail explaining the significance of the Petitioner's past research”

  AAO decision text
• citations publications · discounted

  “citation frequency, which may include self-citations, is quantitative in nature and does not reveal the reasons for the citations”

  AAO decision text
• degree · discounted

  “it is not a sufficient basis to determine that he is well positioned to advance his proposed endeavor”

  AAO decision text
• business plan · discounted

  “does not show that his current work relates to his proposed endeavor such that his current work demonstrates ... evidence of progress”

  AAO decision text
• funding · discounted

  “did not provide copies of research grants showing him as a named grant recipient”

  AAO decision text

Where this case turned

• Citations insufficient · p2 — citation counts without qualitative account of impact
• Education alone insufficient · p2 — degrees offered as positioning — credentials are not a track record
• Funding absent · p2 — no documented funding or resources behind the plan
• Letters conclusory · p2 — letters praise skills in general terms without tracing specific impact
• No progress evidence · p2 — no documented movement toward the endeavor since filing
• Record of success insufficient · p2 — a claimed track record the documents do not establish

Notable

AAO withdrew the Director's prong-one denial, finding national importance established, but dismissed the appeal solely on prong two; it expressly reserved prong three under Bagamasbad/L-A-C- reasoning.

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.

• Flores v. Garland
• Matter of L-A-C-
• USCIS Policy Manual F.5(D)(1)
• USCIS Policy Manual F.5(D)(2)

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