electrical engineering

EB-2 National Interest Waiver — Merits Decision

2025-12-23·DISMISSED·IN RE: 40735056

Underlying petition: DENIED · Service Center Operations (SCOPS)

Legal elements discussed — Matter of Dhanasar

Prong 1 — Substantial Merit & National Importance

FAIL

Petitioner argued: The business would have national scope and broad applicability.

Evidence type: business plan

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

But, even if we accept the higher estimates, he has not explained how a business that generates less than $2 million in annual revenues would substantially affect the U.S. energy market.

Decision PDF, p. 4Open source PDF

Petitioner argued: Past projects in Ecuador had national implications and demonstrate scalability.

Evidence type: recommendation letters, project certifications

USCIS finding: INSUFFICIENT

The record, however, does not demonstrate that any of the Petitioner's past projects in Ecuador had national implications.

Decision PDF, p. 4Open source PDF

Petitioner argued: The proposed endeavor has national importance because it enhances U.S. energy resilience, supports critical infrastructure, aligns with national security goals, promotes economic growth, etc.

Evidence type: recommendation letters, project certifications, business plans

USCIS finding: INSUFFICIENT

The record, however, lacks evidence that the Petitioner's U.S. company would likely work on a project installing 500 miles of isolated aerial power lines or one otherwise generating up to 9,000 jobs.

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 business plan insufficient to establish that the business would have national scope and broad applicability.. 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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