cybersecurity and information assurance

EB-2 National Interest Waiver — Merits Decision

2025-07-03·DISMISSED·IN RE: 39105734

Underlying petition: APPROVED · Service Center Operations (SCOPS)

Legal elements discussed — Matter of Dhanasar

Prong 1 — Substantial Merit & National Importance

FAIL

Petitioner argued: expert opinion letters support national importance

Evidence type: expert opinion letters

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

the expert opinion letters do not specifically mention the Petitioner's endeavor and therefore do not support assertions regarding the proposed endeavor's national importance.

Decision PDF, p. 4Open source PDF

Petitioner argued: letters of interest and collaboration show national significance

Evidence type: letters of interest and collaboration

USCIS finding: INSUFFICIENT

the letters praise the Petitioner's qualifications and professional accomplishments, the Petitioner's skills, expertise, and abilities relate to the second prong of the Dhanasar framework

Decision PDF, p. 4Open source PDF

Petitioner argued: work in cybersecurity would have national importance

Evidence type: recommendation letter

USCIS finding: INSUFFICIENT

the letter does not adequately discuss the proposed endeavor, making only broad statements about the Petitioner's intent to develop AI-powered cybersecurity solutions within the scope of the banking industry, and it offers no explanation as to how the endeavor will 'protect[] the financial well-being of millions of Americans' as to impact the cybersecurity industry or the country as a whole.

Decision PDF, p. 3Open source PDF

Petitioner argued: DHS report and articles show national importance

Evidence type: DHS report and articles

USCIS finding: INSUFFICIENT

neither the report nor the articles specifically mention the Petitioner, his work, or any government interest in the Petitioner's proposed endeavor.

Decision PDF, p. 4Open source PDF

Petitioner argued: proposed endeavor has national importance due to AI-driven cybersecurity initiative and job creation

Evidence type: implementation plan

USCIS finding: INSUFFICIENT

the Petitioner did not provide corroborating evidence in support of these projections or demonstrate that such future staffing levels would result in substantial economic benefits to the region or the U.S. economy more broadly at a level commensurate with national importance.

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 letters insufficient to establish that expert opinion letters support national importance. 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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