dismissed EB-1A Case: Artificial Intelligence

U.S. Citizenship 
and Immigration 
Services 
In Re: 23041135 
Appeal of Texas Service Center Decision 
Non-Precedent Decision of the 
Administrative Appeals Office 
Date: FEB. 16, 2023 
Form 1-140, Immigrant Petition for Alien Worker (Extraordinary Ability) 
The Beneficiary, a product manager, seeks classification as an individual of extraordinary ability in 
the sciences. See Immigration and Nationality Act (the Act) section 203(b)(l)(A), 8 U.S.C. § 
1153(b)(l)(A). This first preference classification makes immigrant visas available to those who can 
demonstrate their extraordinary ability through sustained national or international acclaim and whose 
achievements have been recognized in their field through extensive documentation. 
The Director of the Texas Service Center denied the petition, concluding the record did not establish 
that the Beneficiary qualifies as an individual of extraordinary ability either as the recipient of a one­
time achievement that is a major, internationally recognized award, or at least three of the ten 
regulatory criteria listed at 8 C.F.R. § 204.5(h)(3)(i) - (x). The matter is now before us on appeal. 8 
C.F.R. § 103.3. 
The Petitioner bears the burden of proof to demonstrate eligibility by a preponderance of the evidence. 
Matter of Chawathe, 25 l&N Dec. 369, 375-76 (AAO 2010). We review the questions in this matter 
de nova. Matter of Christa's, Inc., 26 l&N Dec. 537, 537 n.2 (AAO 2015). Upon de nova review, 
we will dismiss the appeal. 
I. LAW 
Section 203(b)(l) of the Act makes visas available to immigrants with extraordinary ability if: 
(i) the alien has extraordinary ability in the sciences, arts, education, business, or 
athletics which has been demonstrated by sustained national or international 
acclaim and whose achievements have been recognized in the field through 
extensive documentation, 
(ii) the alien seeks to enter the United States to continue work in the area of 
extraordinary ability, and 
(iii) the alien's entry into the United States will substantially benefit prospectively 
the United States. 
The term "extraordinary ability" refers only to those individuals in "that small percentage who have 
risen to the very top of the field of endeavor." 8 C.F.R. § 204.5(h)(2). The implementing regulation 
at 8 C.F.R. § 204.5(h)(3) sets forth a multi-part analysis. First, a petitioner can demonstrate 
international recognition of his or her achievements in the field through a one-time achievement (that 
is, a major, internationally recognized award). If that petitioner does not submit this evidence, then 
the petitioner must provide sufficient qualifying documentation that meets at least three of the ten 
criteria listed at 8 C.F.R. § 204.5(h)(3)(i) - (x). 
Where a petitioner meets these initial evidence requirements, we then consider the totality of the 
material provided in a final merits determination and assess whether the record shows sustained 
national or international acclaim and demonstrates that the individual is among the small percentage 
at the very top of the field of endeavor. See Kazarian v. USCIS, 596 F.3d 1115 (9th Cir. 2010) 
(discussing a two-part review where the documentation is first counted and then, if fulfilling the 
required number of criteria, considered in the context of a final merits determination); see also 
Visinscaia v. Beers, 4 F. Supp. 3d 126, 131-32 (D.D.C. 2013); Rijal v. USCIS, 772 F. Supp. 2d 1339 
(W.D. Wash. 2011). 
II. ANALYSIS 
The Beneficiary earned a doctoral degree in "real time, robotic, and automated informatics" from 
I I of Paris and currently serves as a product manager working on 
artificial intelligence projects for the Petitioner. While we do not discuss each piece of evidence, we 
have reviewed and considered each one. 
A. Evidentiary Criteria 
Because the Petitioner has not indicated or established that the Beneficiary received a major, 
internationally recognized award, the Beneficiary must satisfy at least three of the alternate regulatory 
criteria at 8 C.F.R. § 204.5(h)(3)(i) - (x). The Petitioner initially claimed the Beneficiary met six 
criteria, summarized below: 
• (i), Lesser nationally or internationally recognized prizes or awards; 
• (ii), Membership in associations requiring outstanding achievements; 
• (iii), Published material about the alien in professional or major media; 
• (v), Original contributions of major significance; 
• (vi), Authorship of scholarly articles; and 
• (viii), Performing a leading or critical role for distinguished organizations. 
The Director found the Beneficiary met the criteria relating to prizes or awards and to a leading or 
critical role for distinguished organizations, but that the Beneficiary had not satisfied the criteria 
associated with membership, published material, original contributions, or authorship of scholarly 
articles. On appeal, the Petitioner does not assert that the Beneficiary is a member of an association 
2 
that requires outstanding achievements of its members, as judged by national or international experts.1 
However, the Petitioner maintains that the Beneficiary meets each of the other criteria in which the 
Director found in the negative. Upon review, we agree with the Director that the Beneficiary has 
satisfied the prizes or awards and the leading or critical role criteria. Additionally, we conclude that 
the Beneficiary has also satisfied the authorship of scholarly articles criterion. 
Evidence of the alien's authorship of scholarly articles in the field, in professional or 
major trade publications or other major media. 8 C.F.R. § 204.5(h)(3)(vi). 
The regulation at 8 C.F.R. § 204.5(h)(3)(vi) requires the "authorship of scholarly articles in the field, 
in professional or major trade publications or other major media." 2 In general, it should have 
footnotes, endnotes, or a bibliography, and may include graphs, charts, videos, or pictures as 
illustrations of the concepts expressed in the article.3 For other fields, a scholarly article should be 
written for learned persons in the field. Learned persons include all persons having profound 
knowledge of a field.4 
The Petitioner provided evidence of numerous conferences and symposiums in which the Beneficiary 
participated. The Institute of Electrical and Electronics Engineers (IEEE) hosted most of the 
conferences and symposiums from content published in its digital library. The IEEE website states 
that it publishes research and is "a professional association for electronic engineering and electrical 
engineering." The Beneficiary's subfield of artificial intelligence (Al) and robotics is within the 
association's electronic and electrical engineering focus. Therefore, IEEE's published material could 
be considered a professional publication. Accordingly, the record suggests that the Petitioner meets 
the basic parameters applicable to evidence under this criterion. 
With eligibility under this additional criterion, the Beneficiary satisfied part one of this two-step 
adjudicative process. As the Beneficiary has met the initial evidence requirements of at least three 
criteria, it is unnecessary to discuss any additional eligibility claims relating to the regulatory 
provisions at 8 C.F.R. § 204.5(h)(3)(i)-(x). 
B. Final Merits Determination 
As the Petitioner has submitted the requ1s1te initial evidence, we will evaluate whether it has 
demonstrated, by a preponderance of the evidence, that the Beneficiary has sustained national or 
international acclaim and is one of the small percentage at the very top of the field of endeavor, and 
that his achievements have been recognized in the field through extensive documentation. In a final 
merits determination, we analyze a beneficiary's accomplishments and weigh the totality of the 
1 The AAO generally does not address issues that are not raised with specificity on appeal. Issues or claims that are not 
raised on appeal are deemed to be waived. 
2 See generally USCIS Policy Memorandum PM 602-0005.1, Evaluation of Evidence Submitted with Certain Form 1-140 
Petitions; Revisions to the Adjudicator's Field Manual (AFM) Chapter 22.2, AFM Update ADJ 1 -14 6 (Dec. 22, 2010), 
https://www.uscis.gov/policymanual/HTML/PolicyManual.html. 
3 Id at 9. 
4 Id. 
3 
evidence to determine if his successes are sufficient to demonstrate that he has extraordinary ability in 
the field of endeavor.5 In this matter, we determine that the Beneficiary has not shown his eligibility. 
The Beneficiary is a product manager based inl I Pennsylvania. He attained a master's degree 
in control systems from the University of I land a doctoral degree in real time, robotic, and 
automated informatics from the of Paris. He began his career 
working for where he contributed to the creation of two robots! J 
I I acquired and continued the commercialization of 
D 
The record reflects that universities and other researchers in the field utilize both 
to conduct further research. In addition, various retail, restaurant, airport, hospital, and hotel 
businesses use I I robots to improve their service. The Beneficiary co-founded a company, 
I lwhich develops commercial Al products that allow retail stores to automate certain service 
functions. Currently, the Beneficiary works for the Petitioner, a company focused on developing the 
Al systems used in self-driving cars. The Beneficiary garnered awards, performed in a leading critical 
role, and is a named inventor on at least five published patents. Media outlets have interviewed the 
Beneficiary about his company and the Al perception system he helped create. The record, however, 
does not demonstrate that the Beneficiary's personal and professional achievements rise to a level of 
a "career of acclaimed work in the field" as contemplated by Congress. 6 
The Petitioner provided evidence of two awards or prizes that satisfy criterion (i). The record reflects 
the Beneficiary received a 20161 I for the development of software building blocks to add 
smart features to connected devices. The French Ministry ofl I I I in partnership with a French public investment bank, finances I I which is a 
competition to promote the best research and development projects for the finalization of innovative 
technological products. Selected laureates for this competition "must have defined the concept of their 
product and be about to create a company, or have just created it." The laureates' academic level is 
high andl I estimates that over 90% of applicants studied five years or more and 40% hold a PhD. 
The record indicates that tthe winners of the competition receive a cash subsidy in furtherance of their 
project. In 2016,L__Jselected 56 winners from among 347 candidates. 
The Petitioner also submitted evidence that in 2016, I I won a Digital Innovation competition 
award. The Commissariat General for Investment in conjunction with the Investment Program of the 
Future supervises the competition, which accepts applications continuously from companies based in 
France. The competition seeks to "accelerate and amplify developmental projects for innovative 
products or services based on digital technologies." The 2016 competition edition accepted 79 
5 See section 203(b){l){A)(i) of the Act; 8 C.F.R. § 204.5(h)(2), (3); see also Kazarian, 596 F.3d at 1119-20. See generally 
USCIS Policy Memorandum PM 602-0005.1, Evaluation of Evidence Submitted with Certain Form 1-140 Petitions; 
Revisions to the Adjudicator's Field Manual (AFM) Chapter 22.2, AFM Update ADJJ-14 6 (Dec. 22, 2010), 
https://www.uscis.gov/policy-manual/volume-6-part-f-chapter-2 (stating that USCIS officers should then evaluate the 
evidence together when considering the petition in its entirety to determine if the petitioner has established by a 
preponderance of the evidence the required high level of expertise of the immigrant classification). 
6 H.R. Rep. No. 101-723, 59 (Sept. 19, 1990). 
4 
proposals and awarded loans to 19 winners. The record reflects that the Beneficiary's company and 
two other companies received a loan in the category of _____ 
While we acknowledge these awards as meeting the basic parameters applicable to evidence under 
this criterion, the 2016 land Digital Innovations awards do not sufficiently reflect sustained 
national or international acclaim, that the Beneficiary is one of the small percentage at the very top of 
the Al and robotics field, or that his achievements have been recognized in this field. Rather, the 
awards appear to be for excellence in innovation and/or entrepreneurship. Although innovation and 
entrepreneurship may be byproducts of his work, the Beneficiary's claimed field of extraordinary 
ability is not innovation or entrepreneurship specifically. As such, the evidence does not sufficiently 
establish that he received an award commensurate with those among the top of his field. Furthermore, 
the record reflects that the Beneficiary won the awards in 2016 and in conjunction with founding his 
company. The record does not show that the Beneficiary won awards in the field of Al or robotics 
independent of creating a new startup, nor does the evidence sufficiently describe the specific technology 
or services the Beneficiary's company offers.7 
The Petitioner provided documentation of the Beneficiary's receipt of other awards. However, the record 
lacks sufficient evidence with which to establish how the awards meet the basic parameters of the 
criterion. To illustrate, the Petitioner submitted evidence of a tax-free tech-startup loan, which he 
received from I lfor winning a contest. The record includes evidence that in 2016, 
I !awarded a loan to seven startups in the month ofl !awarded the loans after 
contestants gave a one and half minute "pitch" of their idea. The documentation provided does not 
indicate how often I I awards loans (monthly, yearly, or otherwise), how many entrants or 
candidates it considers, or other entry requirement details. The competition appears to be open only 
to those in the Paris region and therefore the record does not demonstrate that thel loan is 
a nationally or internationally recognized award or prize. 
The Petitioner submitted evidence that the Beneficiary received a 2018 I I Retail Award;" 
however, the record does not include sufficient details about the award to draw any conclusions 
concerning the national or international recognition of it. The0Retail Award is a free competition 
for the purpose of identifying companies that offer solutions to issues that e-commerce, retailers, and 
brands face. It is unclear who the competition is open to, but the name suggests that it is open to those 
irl I The documentation does not indicate that the Beneficiary received the award for excellence 
in his field. 
Regarding media coverage, the Director explained that the published material must be about the 
Beneficiary and relate to his work in the field. Both the Director and the Petitioner acknowledged that 
some of the submitted articles lack dates and/or authors, which is a regulatory requirement. The 
Director noted that, "The articles in L 'Usine (no author and no date of publication), 20 Minutes (no 
author and no date of publication), and Daily Mail (no publication date) do not meet the plain language 
7 We acknowledge that one of the letters of recommendation states that sells smart cameras to retailers. However, 
the Petitioner provided little other evidence to support this assertion. 
5 
of this criterion." Some of the articles do not meet the evidentiary criterion for additional reasons. 
The Director explained: 
[T[he article is attributed 
to CNN money with a publication date of 2016. However, there is no indication 
on the material that it was published in CNNmoney. It indicates that the article was 
printed from www.news.mit.edu. Also, there is no circulation data for this 
[(www.news.mit.edu)] news site, and no author or publication date is indicated on the 
material. 
The article in journaldunet.com is both about the Beneficiary and related to his work, as well as has a 
listed author and date. The Petitioner provided readership and circulation data for journaldunet.com, 
which ranks the news source at 512 in France and 14,700 worldwide. The data also includes 
journaldunet.com website traffic statistics. However, the Petitioner has not explained how the data 
shows journeldunet.com is a major medium, nor has it explained the source of the data. Similarly, the 
Petitioner provided readership and circulation data for many of the media outlets referenced; however, 
it is not apparent where this data came from, as there is no website listed or other indication of the 
data's source. In some cases, the data appears to be from the news source itself. However, USCIS 
need not rely on the self-promotional material of the publisher. See Braga v. Poulos, No. CV 06 5105 
SJO (C.D.C.A. July 6, 2007) aff'd 2009 WL 604888 (9th Cir. 2009) (concluding that self-serving 
assertions on the cover of a magazine as to the magazine's status is not reliant evidence of a major 
medium); see also, e.g., Victorov v. Barr, No. CV 19-6948-GW-JPRX, 2020 WL 3213788, at *8 
(C.D.C.A. Apr. 9, 2020). For many other news sources referenced, mostly websites, the Petitioner did 
not provide any information to support a finding that the sources are major media. 
Although the Petitioner provided some articles that mention the Beneficiary or his company, they do 
not appear to be about the Beneficiary and relating to his work in the field. For instance, the Business 
Insider France and the L 'Usine articles appear to be about tech startups, mentioning along 
with other companies. The Economist article ________________ 
contains two short paragraphs about retailers, merely mentions the company the Beneficiary co­
founded, and does not list an author. 
Many articles are about the commercial usage of the robots in various service industry 
contexts. For instance, the Director noted, the 2014 Reuters article! I 
is about the purchase of robots by Nescafe to sell 
coffee makers at electronic stores in Japan, and not about the Beneficiary and/or his work." The 
Petitioner acknowledges that it provided a sampling of articles related to the international and wide­
ranging use of the products the Beneficiary contributed to developing. These articles are not 
necessarily about the Beneficiary and relating to his work in the field. Articles that are not about the 
beneficiary do not fulfill this regulatory criterion. See, e.g., Negro-Plumpe v. Okin, 2:07-CV-820-
ECR-RJJ at *1, *7 (D. Nev. Sept. 8, 2008) (upholding a finding that articles regarding a show are not 
about the actor). 
Les Echos may be considered a major medium and the article it published has all the required 
regulatory elements. In addition, the content is also about the Beneficiary's company. However, the 
four-paragraph article interviews the Beneficiary's co-founder, not the Beneficiary. While the article 
6 
mentions the Beneficiary, the evidence overall is indicative neither of sustained acclaim nor of the 
Beneficiary's status as one of the small percentage at the very top of the field of endeavor. 
The Petitioner emphasized that it submitted nearly fifty articles. While the Petitioner offered a 
significant volume of evidence, eligibility for the benefit sought is not determined by the quantity of 
evidence alone but also the quality. Chawathe, 25 l&N Dec. at 376 (citing Matter of E-M-, 20 l&N 
Dec. 77, 80 (Comm'r 1989)). The Petitioner bears the responsibility of ensuring that the record 
demonstrates how the Beneficiary qualifies for the requested benefit. Section 291 of the Act, 8 U.S.C. 
§ 1361. We acknowledge the Petitioner's assertion that the Director ignored evidence. However, 
when USCIS provides a reasoned consideration to the petition, and has made adequate findings, it will 
not be required to specifically address each claim the Petitioner makes, nor is it necessary for it to 
address every piece of evidence the Petitioner presents. See Guaman-Loja v. Holder, 707 F.3d 119, 
123 (1st Cir. 2013) (citing Martinez v. INS, 970 F.2d 973, 976 (1st Cir.1992); see also Kazemzadeh v. 
U.S. Atty. Gen., 577 F.3d 1341, 1351 (11th Cir. 2009); Casalena v. U.S. INS, 984 F.2d 105, 107 (4th 
Cir. 1993). 
As noted regarding scholarly articles, the record contains evidence of numerous conferences and 
symposiums in which the Beneficiary participated. IEEE hosted most of these conferences and 
symposiums based on content published in its digital library. The Beneficiary is a named author on 
the publications, most of which were published in 2008 and 2009, during which time the Beneficiary 
pursued his doctoral degree. The evidence does not suggest that the Beneficiary continues to publish 
or offer original research. Further, the Petitioner provided little information on what IEEE is and does, 
how it determines what it publishes, or the intended audience of the publications. 
In its request for evidence (RFE) response, the Petitioner quoted the USCIS Policy Manual for the 
assertion that "peer-reviewed presentations at academic symposia or peer-reviewed articles in 
scholarly journals that have provoked widespread commentary or received notice from others working 
in the field ... may be probative of the significance of the person's contributions to the field of 
endeavor."8 Although the portion of the Policy Manual in which this appears relates to the criterion of 
original contributions of major significance, the Director nevertheless considered the Petitioner's 
assertion under the authorship of scholarly articles criterion. 9 
The Petitioner offered evidence of the Beneficiary's 128 citations in Google Scholar. However, the 
record does not contain sufficient comparative evidence to establish the relative significance of this 
number of citations. In other words, it is not apparent that the Beneficiary's work has provoked 
widespread commentary or received notice from others working in the field based upon 128 citations. 
Although articles mentioning I !received considerably more citations, the Petitioner has 
not offered sufficient evidence to explain whether the Beneficiary authored thel articles 
and whether they would be considered scholarly. Therefore, we cannot confer thel I 
citation history upon the Beneficiary in the context of the Beneficiary's authorship of scholarly 
articles. Regarding the Beneficiary's citation history as it pertains to the significance of his 
contributions to the field, the Director noted that the Petitioner did not submit sufficient "evidence to 
8 See generally USCIS Policy Memorandum PM 602-0005.1, supra, at 8-9. 
9 On appeal, the Petitioner pivots from away from its RFE position and criticizes the Director's decision for considering 
whether the articles provoked widespread commentary or received notice from others working in the field. 
7 
demonstrate that this number of citations is indicative of major significance in the Beneficiary's field." 
We similarly conclude that the Petitioner has offered insufficient comparative evidence to establish 
widespread commentary or notice from others in the field. 
Regarding contributions to the field, the Petitioner provided evidence of the Beneficiary's patents and 
that other researchers have built upon the systems he created. As the Director noted, the patents and 
other evidence support a finding of originality, but do not necessarily support a finding that his 
contributions were of major significance in the field. The Director explained that "[i]nnovative 
contributions that lead to commercial success for the employer are commendable, but are insufficient 
if they do not demonstrate that the contributions made a major impact in the field of endeavor as a 
whole." Although the Beneficiary's former employer may have sold hundreds or thousands of 
I I robots to various service industries internationally, such evidence demonstrates 
commercial success for the employer and a contribution to the service industry more than the 
Beneficiary's field. Even if the Petitioner had provided sufficiently detailed information regarding 
I Isales, it would not necessarily support a finding that the patented systems within the 
robots are available to the field as a whole. Even if we assume the patents' publication makes the 
underlying perception system within thel I available to the scientific community, the 
Petitioner has not demonstrated that the acclaim! !received can be conferred upon the 
Beneficiary such that his specific contributions are of major significance. 
The Petitioner provided various abstracts of other researchers who use thel I robots to 
conduct research. In addition, articles and letters of recommendation support the finding that others 
in the scientific community have built u on the technology. The record reflects that 
researchers may have purchased a ___ robot to use as the platform upon which they test 
their own systems. Although the record reflects that the Beneficiary contributed to the creation of the 
I robots, the evidence provided does not sufficiently connect the Beneficiary's specific 
contribution of the perception systems to the success of the robots. For instance, the majority if not 
all of media articles discussing I do not mention the Beneficiary or his perception 
system contribution specifically. While these articles are significant and probative, they do not 
sufficiently support a finding that the Beneficiary has risen to the very top of his field. Furthermore, 
the record does not sufficiently reflect that the Beneficiary has sustained acclaim as a result of the 
I !robots, as opposed to achieving a level of temporary acclaim. 
Similarly, although the robots may be the standard platform for an international robotics competition, 
the evidence suggests that the hosts selected I I because they offer tracking features 
useful in monitoring the contestants. It is not apparent that the Beneficiary's contribution to the 
technology within the robots has been of major significance in the field as a result of the competition 
selecting ltor its monitoring and tracking capabilities. 
Although the Petitioner provided basic evidence to establish the Beneficiary's eligibility under the 
criterion related to performing a leading or critical role within distinguished organizations or 
establishments, the Petitioner did not provide strong evidence of the distinguished reputation of 
The Petitioner provided evidence of I I size and reputation in 
the field, which the Director found sufficient to establish I I distinguished reputation. 
However, the record does not clearly reflect whether the Beneficiary worked for I I 
Rather, it appears that he worked tori I before _____ acquired it. 
8 
Therefore, evidence of I reputation cannot necessarily be conferred upon I I I I In addition, the Beneficiary's leading or critical role at one company during a limited period 
of employment does not sufficiently support a finding that he has sustained acclaim.10 
The Petitioner submitted evidence that the Beneficiary participated in a temporary working group which 
the French government initiated. Documentation about the group states that "[f]or two months, 
researchers, companies, start-ups and institutional players will come together to help define France's 
broad guidelines for artificial intelligence." The document reflects that the organizers of the group placed 
the Beneficiary as a member of a 23-person subgroup entitled the "national development of the ecosystem 
of French AT technologies suppliers and their use." The evidence does not indicate that the Beneficiary 
leads his subgroup, how the organizers selected the Beneficiary for participation, or how the Beneficiary 
contributed to the group. The document does not clearly reflect the total number of participants in the 
working group; however, the list is ten pages long, single spaced, and contains 17 subgroups.11 Although 
the French government's selection of the Beneficiary for participation in the working group demonstrates 
his expertise in Al, it does not sufficiently demonstrate that the Beneficiary is among the small percentage 
at the very top of the field of endeavor. 
In summary, the Beneficiary seeks a highly restrictive visa classification, intended for individuals 
already at the top of their respective fields. USCIS has long held that even athletes performing at the 
major league level do not automatically meet the "extraordinary ability" standard.12 The Petitioner's 
evidence confirms the Beneficiary received attention from those in his field. However, considering the 
full measure of the Beneficiary's ability and achievements, the level of his national or international 
acclaim, and the extent to which his achievements have been recognized in the field, we conclude that the 
evidence is not indicative of a record of sustained acclaim. The Petitioner has not sufficiently documented 
how the Beneficiary has attained a level of expertise placing him among that small percentage that has 
risen to the very top of the field of endeavor. 
Ill. CONCLUSION 
For the reasons discussed, the Petitioner has not demonstrated the Beneficiary's eligibility as an 
individual of extraordinary ability. The appeal will be dismissed for the above stated reasons. In visa 
petition proceedings, it is a petitioner's burden to establish eligibility for the immigration benefit 
sought. The Petitioner has not met that burden here. 
ORDER: The appeal is dismissed. 
10 While we acknowledge the Petitioner's statement that the Beneficiary currently holds a leadership role, it is unclear 
when his leading or critical role began. The Petitioner must establish eligibility at the time of filing for the requested 
benefit. 8 C.F.R. § 103.2(b)(l). 
11 Some names appear more than once. Accordingly, a simple count of the names on the list does not necessarily reflect 
the number participants overall. In addition, although the Petitioner provided 10 pages of names, the page numbers do not 
appear to match. For instance. after the page "6 of 6," the pages continue as "7 of 6," "8 of 6," "9 of 6," and "10 of 6." 
We cannot determine what this means or whether the evidence represents the complete list of participants. 
12 Matter of Price, 20 l&N Dec. 953, 954 (Assoc. Comm'r 1994). 
9