semiconductor manufacturing

EB-2 National Interest Waiver — Merits Decision

2026-01-13·DISMISSED·IN RE: 40803358

Underlying petition: DENIED · Service Center Operations (SCOPS)

Legal elements discussed — Matter of Dhanasar

Prong 1 — Substantial Merit & National Importance

FAIL

Petitioner argued: The proposed endeavor has national importance due to semiconductor shortage and broader implications for the industry.

Evidence type: expert opinion letter

U.S. Citizenship and Immigration Services (USCIS) finding: INSUFFICIENT

the expert opinion letter is of little probative value as it conflates the importance of the field overall with the national importance of the Beneficiary's specific endeavor

Decision PDF, p. 4Open source PDF

Petitioner argued: The proposed endeavor has national importance due to government initiatives like CHIPS Act.

Evidence type: articles about U.S. government initiatives

USCIS finding: INSUFFICIENT

Although this evidence provides background information on the industry itself: and government efforts to support the industry; without sufficient documentary evidence of the specific proposed endeavor's broader impact on the industry, the Beneficiary's proposed endeavor does not meet the 'national importance' element of the first prong of the Dhanasar framework.

Decision PDF, p. 3Open source PDF

Prong 2 — Well Positioned to Advance the Endeavor

NOT_DISCUSSED

Prong 3 — Balancing the Waiver's Benefits

NOT_DISCUSSED

What this decision can’t tell you

This decision comes from a case that was denied and then appealed. Every case here is in that position — it cannot be used to estimate an overall approval rate, and it cannot predict the outcome of any individual case, including yours. USCIS officers exercise discretion on facts that are never fully captured in a written decision.

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Questions this raises for your lawyer

  • On Prong 1 (substantial merit & national importance), USCIS found the petitioner's expert opinion letter insufficient to establish that the proposed endeavor has national importance due to semiconductor shortage and broader implications for the industry.. What would make comparable evidence in my own case more persuasive?
  • What in my own case most resembles the specific facts USCIS focused on in this decision?
  • Would additional expert-opinion evidence have changed the outcome here, based on what USCIS said was missing?
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