The Petitioner sought to work as an expert quality management systems (QMS) consultant for American businesses nationwide, running her own small consulting company serving small-business clients.

Prong 1 — national importancenot established · dispositive

“The relevant question when determining an endeavor's national importance is not the importance of the industry or profession where the Petitioner will work, but the specific impact of that proposed endeavor.”

“there is insufficient information about the size and prominence of the client company to establish that the Petitioner's work for them has the potential to impact the broader food industry on a national level.”

“the record does not examine these figures in the context of the local, state, or national economy, and so does not establish that the company's business activity would constitute a significant economic benefit”

“No explanation is provided for how the company will obtain a physical office space with no rental costs and no utility expenses beyond those required for a company operating virtually.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “there is no indication in the letter that the Petitioner's work has had or will have any relationship to food safety”

  AAO decision text
• business plan · discounted

  “she has not provided documentation specifying how her work for 15 small companies is more likely than not to impact the food industry”

  AAO decision text
• other · discounted

  “the record does not examine these figures in the context of the local, state, or national economy”

  AAO decision text
• certification membership · ignored

  “these factors relate to the second prong of the Dhanasar test... They do not establish what potential impact the endeavor would have.”

  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
• 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

The AAO explicitly separates 'merit' from 'national importance,' finding the Petitioner's arguments about industry-wide importance of quality management conflated the two; it also critiques an EPI economic-impact calculation as unmoored from any specific geographic economic context, and notes an unexplained inconsistency in the business plan's second-year budget regarding office rent/utilities.

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 Ho
• Matter of L-A-C-

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