The Petitioner, a project engineer with over 30 years of experience, proposed to advance his career through leadership positions and by founding his own engineering project management/consulting company offering control systems, industrial automation, and project engineering consulting, custom control valve products, and technical training.

Prong 1 — national importancenot established · dispositive

“the Petitioner did not establish that his proposed endeavor has national importance and thus, he did not meet the national importance requirement of the first prong”

“Benefits to a specific employer alone, even an employer with a national footprint, are not sufficiently relevant to the question of whether a person's endeavor has national importance.”

“the plan does not sufficiently detail the basis for the revenue and staffing projections, nor does it adequately explain how the revenue and staffing projections will be realized”

“the relevant question is not the importance of the field, industry, or profession in which the individual will work”

“the letters describe the Petitioner's job duties, rather than describing achievements that had broad implications to the field of project engineering”

“his opinion is general in nature, concluding that, because the Petitioner's proposed endeavor is to improve industrial automation, it has national importance”

AAO decision text

How the evidence was treated

• business plan · discounted

  “generalized projections that are not specific and detailed enough to establish the potential prospective impact of his proposed endeavor”

  AAO decision text
• recommendation letter · discounted

  “describe the Petitioner's job duties, rather than describing achievements that had broad implications to the field”

  AAO decision text
• other · discounted

  “the advisory opinion is of little probative value as it does not meaningfully address the details of the Petitioner's specific proposed endeavor”

  AAO decision text
• resume experience · discounted

  “the Petitioner's skills, expertise, and abilities relate to the second prong of the Dhanasar framework”

  AAO decision text
• certification membership · ignored

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
• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• 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
• Derivative of Prong 1/2 failure · p3 — prong three fails only because prongs one or two did — no independent ground

Notable

AAO discussed the SBA HUBZone program at length, rejecting Petitioner's attempt to use HUBZone location as evidence of 'substantial positive economic effects, particularly in an economically depressed area' under Dhanasar, finding he had not shown HUBZone certification eligibility and that the argument was 'too amorphous.' Footnote 5 provides an alternative holding that even if all prongs were reached, the appeal would still be dismissed because Petitioner submitted no new evidence on appeal.

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.

• Matter of L-A-C-
• Poursina v. USCIS

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