The Petitioner proposed to build a telemedicine consultancy/platform connecting patients with health professionals via kiosks, computers, tablets, and mobile devices to improve healthcare access for rural and migrant populations in Florida and Puerto Rico.

Prong 1 — national importancenot established · dispositive

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

“providing consulting services in an area that is adjacent to the subject of national initiatives is not sufficient, in and of itself, to establish the national importance of a specific endeavor”

“he has not offered evidence, such as documentation showing that he has received ARPA funding, or letters demonstrating U.S government agencies' or quasi-governmental agencies interest in his proposed endeavor”

“The business plan does not adequately explain how these staffing projections were calculated.”

“they do not demonstrate that benefits to the regional or national economy resulting from the Petitioner's undertaking would reach the level of "substantial positive economic effects" contemplated by Dhanasar”

AAO decision text

How the evidence was treated

• business plan · discounted

  “The business plan does not adequately explain how these staffing projections were calculated.”

  AAO decision text
• other · discounted

  “they do not specifically show the government's interest in the Petitioner's proposed endeavor”

  AAO decision text
• other · discounted

  “these articles generally discuss rural health in America, and the importance of telemedicine in improving health outcomes”

  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
• 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

Notable

Petitioner raised a procedural due-process/abuse-of-discretion argument under Buletini v. INS, claiming the Director failed to consider the totality of evidence; AAO rejected this, holding USCIS need not individually address every piece of evidence so long as reasoned consideration was given. AAO also clarified the Director had improperly conflated the vacated NYSDOT 'national in scope' standard with Dhanasar's national importance prong, but found this conflation was not the sole basis for denial and thus not reversible error.

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
• Buletini v. INS
• Flores v. Garland
• Matter of L-A-C-
• Matter of NYSDOT

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