The petitioner, a computer scientist, sought to continue developing AI algorithms and machine learning models—particularly for graph and network analysis—applied to healthcare challenges such as precision medicine, drug interaction modeling, and drug discovery.

Prong 1 — national importanceestablished

“As the Petitioner has demonstrated both the substantial merit and national importance of her proposed research, she has established that she meets the first prong of the Dhanasar framework.”

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.”

“The Petitioner's citation record must be weighed alongside other qualitative indicators of impact and influence.”

“the authors of these letters and opinions do not provide sufficient detail explaining the significance of the Petitioner's past research”

“the record lacks sufficient detail regarding the Petitioner's special role or responsibilities in securing these fonds”

“the Petitioner has not sufficiently demonstrated how she plans to carry out her proposed research activities”

“the Petitioner has not provided evidence of progress toward achieving the specific goals of her proposed endeavor”

AAO decision text

How the evidence was treated

• recommendation letter · discounted

  “the authors of these letters and opinions do not provide sufficient detail explaining the significance of the Petitioner's past research”

  AAO decision text
• citations publications · discounted

  “citation frequency, which may include self-citations, is quantitative in nature and does not reveal the reasons for the citations”

  AAO decision text
• funding · discounted

  “the Petitioner has not shown that she was the primary award recipient or principal investigator”

  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
• resume experience · discounted

  “she has not sufficiently demonstrated how she is well positioned to advance her research endeavor while working for”

  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
• Letters conclusory · p2 — letters praise skills in general terms without tracing specific impact
• 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

AAO expressly withdrew SCOPS' prong-1 (national importance) denial and credited the endeavor's merit, but still dismissed the appeal solely on prong 2, reserving prong 3. The Petitioner argued SCOPS abused its discretion and applied a 'heightened standard,' citing Buletini v. INS; AAO rejected this, holding USCIS need not individually address every piece of evidence, citing Villegas Sanchez v. Garland.

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-
• USCIS Policy Manual F.5(D)(2)

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