The Petitioner sought to run her own business providing legal consulting on Kazakhstan law, attracting foreign investment and STEM specialists from Kazakhstan, and converting abandoned U.S. real estate ('zombie houses') into affordable homes.

Prong 1 — national importancenot established · dispositive

“the Petitioner has not identified her endeavor with sufficient specificity”

“the proposed endeavor, as described, is overly expansive in scope such that it obfuscates the endeavor's impact and broader implications”

“she has not provided sufficient evidence to establish how her proposed endeavor will operate on such a scale as to impact these matters on a level commensurate with national importance”

“The authors did not explain how the Petitioner's performance or the results she achieved extended beyond her clients and the specific parties involved to impact the field more broadly”

“the relevant question is not the importance of the industry or profession in which the individual will work; instead, we focus on the "the specific endeavor"”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “does not explain how the Petitioner's specific proposed endeavor has national importance”

  AAO decision text
• media · discounted

  “they do not analyze the national importance of the Petitioner's specific proposed endeavor”

  AAO decision text
• other · discounted

  “she has not demonstrated with specificity how the facts and evidence in these cases are analogous to her own”

  AAO decision text

Where this case turned

• 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
• Letters not independent · p1 — letters come from employers and close collaborators, not independent experts

Notable

AAO found the petitioner's endeavor impermissibly expanded and diffuse (a 'cobbled together' list of many activities including legal consulting, real estate conversion, investment attraction, database creation, and book publishing), holding this lack of specificity alone precluded a national importance finding; declined to reach prongs 2 and 3 as unnecessary.

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

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