cognitive artificial intelligence (AI)

EB-2 National Interest Waiver — Merits Decision

2026-02-09·DISMISSED·IN RE: 40211929

Underlying petition: DENIED · Service Center Operations (SCOPS)

Legal elements discussed — Matter of Dhanasar

Prong 1 — Substantial Merit & National Importance

NOT_DISCUSSED

Prong 2 — Well Positioned to Advance the Endeavor

FAIL

Petitioner argued: Petitioner's citation record demonstrates impact

Evidence type: Google Scholar citation record, Clarivate Analytics percentile ratings

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

The Petitioner's bibliometrics evidence is unpersuasive to establish the significance of his citation record and research to the larger field of cognitive AI

Decision PDF, p. 5Open source PDF

Petitioner argued: Ardent's interest in employing Petitioner demonstrates interest from relevant entities

Evidence type: offer letter

USCIS finding: INSUFFICIENT

the letter provided is undated and appears to postdate the filing of the petition

Decision PDF, p. 5Open source PDF

Petitioner argued: Petitioner's proposed endeavor is distinct from his employment

Evidence type: personal statement

USCIS finding: INSUFFICIENT

it is unclear what the Petitioner's proposed endeavor would look like independent of his position

Decision PDF, p. 5Open source PDF

Petitioner argued: Petitioner has a record of success and interest from relevant parties due to publications and grant funding

Evidence type: publications, citation record, grant letters

USCIS finding: INSUFFICIENT

we agree with SCOPS that the Petitioner has not satisfied his burden.

Decision PDF, p. 3Open source PDF

Petitioner argued: Petitioner's research is funded by NASA and NSF

Evidence type: letters from Dr. M.H., published articles with grant acknowledgements

USCIS finding: INSUFFICIENT

the evidence provided does not show that the Petitioner's research is funded through these U.S. government entities.

Decision PDF, p. 4Open source PDF

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.

This decision turned on whether the person was well-positioned to advance the endeavor. Describe your own work and see which decisions discussed the same issue.

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Questions this raises for your lawyer

  • On Prong 2 (well positioned to advance the endeavor), USCIS found the petitioner's Google Scholar citation record, Clarivate Analytics percentile ratings insufficient to establish that petitioner's citation record demonstrates impact. 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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