The Petitioner, a cross-cultural leadership specialist with a background in education, proposed to advise and consult with U.S. businesses on managing diverse teams and improving cross-cultural leadership practices.

Prong 1 — national importancenot established · dispositive

“the record did not establish her proposed employment activities has the potential to extend beyond her prospective employer's business and its clients to impact her field of endeavor at a level commensurate with national importance.”

“The Petitioner has not provided corroborating evidence to support her claims that her employment activities as a cross-cultural leadership specialist for a U.S. business stands to provide substantial economic and social welfare benefits to the United States.”

“Instead, of focusing on the importance of an industry or the need for workers in a specific industry, we focus on the "the specific endeavor that the foreign national proposes to undertake."”

“The content of the opinion is lacking relevance because it discusses the importance of education and how the Petitioner's expertise would be beneficial to her proposed teaching activities, instead of focusing on the Petitioner's indicated endeavor of providing her cross-cultural leadership services to U.S. businesses.”

“Where an opinion is not in accord with other information or is in any way questionable, USCIS is not required to accept it or may give it less weight.”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “The submission of letters from experts supporting the petition is not presumptive evidence of eligibility.”

  AAO decision text
• resume experience · discounted

  “Her academic credentials and professional experience relate to the second prong of the Dhanasar framework”

  AAO decision text
• other · ignored

  “The Petitioner did not explain the relevance of these separate job opportunities in relation to her proposed endeavor”

  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
• 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
• Occupational shortage argument rejected · p1 — argues a labor shortage — the labor-certification question, not Dhanasar

Notable

AAO limited its national-importance analysis strictly to the endeavor as stated in the petition/professional plan, disregarding job-search printouts (ESL instructor, Portuguese teacher, etc.) submitted with the RFE response as irrelevant to the stated endeavor; also discounted a supporting expert opinion because it discussed teaching activities not actually part of the claimed endeavor.

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)
• INA 203(b)(2)
• Matter of D-R-
• Matter of E-M-
• Matter of L-A-C-
• Poursina v. USCIS

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