The Petitioner sought to work as an investment trust manager for a U.S. employer while also proposing, alternatively, to operate her own financial consulting business advising on commercial property investment risk and financial literacy.

Prong 1 — national importancenot established · dispositive

“it remains unclear whether the Petitioner seeks to work fo~ lor offer consulting services independently through her own business.”

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

“the Petitioner has not sufficiently explained or demonstrated how her employment would independently lead to economic growth or job creation nationwide.”

“merely working in an important field and the endeavor's alignment with government initiatives alone 1s insufficient for national importance.”

“the record as a whole remains insufficient to demonstrate that her proposed endeavor will extend beyond her company and its prospective clientele”

AAO decision text

How the evidence was treated

• business plan · discounted

  “her plan is scalable and replicable... insufficient for national importance”

  AAO decision text
• other · discounted

  “The Petitioner must support her assertions with relevant, probative, and credible evidence.”

  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
• Local, not national scope · p1 — impact confined to clients / a region

Notable

AAO noted the Petitioner presented two 'dueling proposed endeavors' (employment vs. self-employment consulting) and held that this lack of a clearly defined endeavor itself undermined the national importance analysis, though it proceeded to analyze both alternatives anyway.

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)(12)
• 8 C.F.R. 103.3
• 8 C.F.R. 103.5
• Flores v. Garland
• Matter of Katigbak
• Matter of L-A-C-

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