The Petitioner proposed to develop optimized operational techniques for integrated power systems to create more sustainable and efficient energy solutions, pursuing this while completing a PhD and postdoctoral research position.

Prong 1 — national importanceestablished

“The Director determined that the Petitioner's proposed endeavor has both substantial merit and national importance and we agree.”

AAO decision text

Prong 2 — well positionednot established · dispositive

“A degree in and of itself is not a basis to determine that a person is well positioned to advance the proposed endeavor.”

“we may not assume that every article published in a high-ranking journal is indicative of a record of success”

“citation frequency which is quantitative in nature does not reveal the reasons for the citations, which involve a qualitative analysis”

“the Petitioner did not establish how this temporary job well positions him to advance his proposed endeavor”

“the record does not show that the Petitioner, as opposed to the University for example, has received funding for his research proposals or future projects”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the Petitioner did not demonstrate that his citatory evidence reflects a record of success in the field”

  AAO decision text
• citations publications · discounted

  “citation frequency which is quantitative in nature does not reveal the reasons for the citations”

  AAO decision text
• degree · discounted

  “A degree in and of itself is not a basis to determine that a person is well positioned to advance the proposed endeavor”

  AAO decision text
• funding · discounted

  “the record does not show that the Petitioner...has received funding for his research proposals or future projects”

  AAO decision text
• resume experience · discounted

  “the Petitioner did not establish how this temporary job well positions him to advance his proposed endeavor”

  AAO decision text

Where this case turned

• Citations insufficient · p2 — citation counts without qualitative account of impact
• Education alone insufficient · p2 — degrees offered as positioning — credentials are not a track record
• Funding absent · p2 — no documented funding or resources behind the plan
• No progress evidence · p2 — no documented movement toward the endeavor since filing
• Record of success insufficient · p2 — a claimed track record the documents do not establish

Notable

Petitioner argued the Director applied an extraordinary-ability-like heightened standard under prong 2 and that the RFE-copied analysis showed failure to consider the totality of evidence (citing Buletini v. INS); AAO rejected both arguments, holding the Director's language mapped to Dhanasar's second-prong factors and that USCIS need not address every piece of evidence. AAO declined to reach prong 3 given prong 2 failure.

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
• Matter of E-M-
• Matter of L-A-C-
• USCIS Policy Manual F.5(D)(2)

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