The Petitioner proposed to work as a consultant providing marketing and digital innovation advisory services to small and medium-sized businesses owned by underserved populations, aiming to help them use technology to compete.

Prong 1 — national importancenot established · dispositive

“the record does not establish that his endeavor will meaningfully impact the industry he intends to serve, beyond his immediate customers”

“the Petitioner has not supported this assertion with evidence that establish the economic impact of his specific endeavor, rather than relying on the industry and importance of small and medium-sized businesses in general”

“The articles do not discuss the Petitioner's work or his proposed endeavor, but rather establish the importance of the consulting field and the use of digital tools in business promotion”

“he has not offered evidence to corroborate his claims that his business will in fact operate in an IRS opportunity zone”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the evidence does not establish broader implications from his work”

  AAO decision text
• other · discounted

  “they do not establish its national importance as contemplated in Dhanasar”

  AAO decision text
• resume experience · ignored

  “a petitioner's expertise and record of success are considerations under Dhanasar's second prong”

  AAO decision text

Where this case turned

• 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

AAO extensively rebuts Petitioner's abuse-of-discretion argument and reliance on Buletini v. INS, citing multiple circuit court cases (Ren, Osuchukwu) for the proposition that USCIS need not address every piece of evidence individually. Also notes Petitioner's unsupported claim about operating in an IRS-designated opportunity zone.

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
• 8 C.F.R. 204.5(k)(2)
• Buletini v. INS
• Flores v. Garland
• INA 203(b)(2)
• Matter of L-A-C-

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