pharmaceutical manufacturing

EB-2 National Interest Waiver — Merits Decision

2025-11-10·DISMISSED·IN RE: 40101810

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 will have economic implications and create jobs.

Evidence type: letters from past and current employers

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

the record lacks specificity. For example, the Petitioner does not include information about what types of jobs his specific proposed endeavor will create, where they will be created, how many jobs he will create, how his proposed endeavor will impact the economy, and if it will impact an economically depressed area.

Decision PDF, p. 4Open source PDF

Petitioner argued: The proposed endeavor has national importance due to its impact on pharmaceutical manufacturing, drug affordability, and alignment with U.S. policy priorities.

Evidence type: industry reports, articles, job offer letter, job description, letters of recommendation, professional plan

USCIS finding: INSUFFICIENT

the Petitioner's proposed endeavor does not meet the standard for national importance set forth in the Dhanasar framework.

Decision PDF, p. 3Open source PDF

Petitioner argued: The proposed endeavor includes publishing research, engaging in regulatory discussions, speaking at conferences, and mentoring future leaders.

Evidence type: professional plan

USCIS finding: INSUFFICIENT

the Petitioner does not support this research plan with relevant, probative, and credible evidence.

Decision PDF, p. 4Open 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 letters from past and current employers insufficient to establish that the proposed endeavor will have economic implications and create jobs.. 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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