The Petitioner, a Ph.D. student in informatics, proposes to develop human-centered AI systems that integrate human cognitive and behavioral nature with AI to promote safer and more equitable AI applications across healthcare, finance, and education sectors. She intends to pursue this through research scientist roles and peer-reviewed publications in conference proceedings and academic journals.

Prong 1 — national importancenot established · dispositive

“the evidence submitted to support her claims does not discuss the Petitioner's specific research work or establish its national importance.”

“the importance of this field does not establish the national importance of the Petitioner's proposed endeavor in particular.”

“she has not provided the level of specific details or documentation as required under Matter of Dhanasar to support her claims”

“The Petitioner mainly relies on her statements, without sufficient corroborating evidence, to characterize her proposed research work as valuable”

“Dr. H. K. does not discuss the Petitioner's future proposed endeavor nor the Petitioner's three intended research projects and their national importance.”

“this evidence does not demonstrate a sufficiently direct connection between her proposed area of research and any potential broad impacts on the field of AI”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “Dr. H. K. speaks highly of the Petitioner, he does so in mostly general terms.”

  AAO decision text
• other · discounted

  “these articles and reports do demonstrate the potential impact that AI may have on the global economy... we conclude that they are not sufficiently probative as to the national importance of the Petitioner's endeavor.”

  AAO decision text
• other · discounted

  “the proposed endeavor's relation to a STEM field, and specifically a CET, does not establish its national importance.”

  AAO decision text
• resume experience · discounted

Where this case turned

• 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
• Letters conclusory · p1 — letters praise skills in general terms without tracing specific impact

Notable

The AAO explicitly addressed and partially credited the Petitioner's argument that SCOPS improperly conflated her proposed endeavor with her specific employment as a research scientist, but ultimately agreed with SCOPS on the national importance finding. The AAO drew a direct comparison to the Dhanasar petitioner's hypersonic propulsion research (including government funding) to illustrate the evidentiary gap. The Petitioner's initial statement of intent to work at Google was later walked back in the RFE response to a broader set of potential employers, which the AAO noted impeded assessment of prospective impact. The decision also references a 2025 OMB memorandum on AI risk management practices as contemporaneous policy evidence.

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