The Petitioner, who had worked as a business manager at a Brazilian language school, initially proposed to work in the U.S. as a business manager/administration professional, but later reframed her endeavor as founding a consultancy, assistance, and training company in corporate administrative management.

Prong 1 — national importancenot established · dispositive

“she provided no further details about her intended work in the United States.”

“the Petitioner's initial description of the proposed endeavor did not include or imply such plans.”

“The overall significance of the entire field of management consulting does not establish the national importance of one patiicular management consulting firm.”

“the record does not show that the beneficiary's proposed endeavor stands to sufficiently extend beyond her future employer and its clientele to impact her field more broadly at a level commensurate with national importance.”

“The Petitioner has not shown that her proposed endeavor would yield that level of job creation.”

“her claims about how the proposed endeavor satisfied the Dhanasar requirements changed significantly after the Director issued the RFE.”

AAO decision text

How the evidence was treated

• business plan · discounted

  “consist of general statements about various beneficial concepts, sometimes with little or no explanation of their relevance to the proposed endeavor”

  AAO decision text
• resume experience · credited
• other · discounted

  “The policy guidance does not create a presumption of eligibility for entrepreneurs.”

  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
• Employer-specific benefit · p1 — "work furthers my company's product" — value accrues to one firm
• 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
• Material change of endeavor · p1 — the endeavor described on appeal is not the one filed

Notable

The AAO's analysis centers on the Petitioner having materially shifted her proposed endeavor mid-adjudication—from being a 'business manager' for an unspecified employer to founding her own consultancy—after citing USCIS entrepreneur guidance in response to the RFE. The AAO treated this shift as undermining, rather than merely elaborating, her national importance claim, and found the change dispositive without reaching prongs two or three.

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. 103.2(b)(1)
• 8 C.F.R. 103.3
• Matter of L-A-C-
• Poursina v. USCIS

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