dismissed EB-1A Case: Electrical Engineering

U.S. Citizenship 
and Immigration 
Services 
MATTER OF P-T- LLC 
Non-Precedent Decision of the 
Administrative Appeals Office 
DATE: OCT. 21, 2019 
APPEAL OF NEBRASKA SERVICE CENTER DECISION 
PETITION: FORM 1-140, IMMIGRANT PETITION FOR ALIEN WORKER 
The Petitioner , an electrical products manufacturer, seeks to classify the Beneficiary as an individual 
of extraordinary ability. See Immigration and Nationality Act (the Act) section 203(b )(1 )(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 Nebraska Service Center denied the petition, concluding that the Petitioner 
established that the Beneficiary satisfied only two of the ten initial evidentiary criteria, of which he 
must meet at least three. 
On appeal, the Petitioner submits additional evidence and asserts that the Beneficiary meets at least 
four of the ten evidentiary criteria and qualifies for the requested classification. 
Upon de nova review, we will dismiss the appeal. 
I. LAW 
Section 203(b )(1 )(A) of the Act makes visas available to qualified 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. 
Matter of P-T-LLC 
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 two options for satisfying this classification's initial evidence 
requirements. First, a petitioner can demonstrate a one-time achievement (that is, a major, 
internationally recognized award). If that petitioner does not submit this evidence, then he or she must 
provide documentation that meets at least three of the ten categories listed at 8 C.F.R. 
§ 204.5(h)(3)(i) - (x) (including items such as awards, published material in certain media, and 
scholarly articles). 
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). This two-step analysis is consistent with our holding that the "truth is to be 
determined not by the quantity of evidence alone but by its quality," as well as the principle that we 
examine "each piece of evidence for relevance, probative value, and credibility, both individually and 
within the context of the totality of the evidence, to determine whether the fact to be proven is probably 
true." Matter of Chawathe, 25 I&N Dec. 369, 376 (AAO 2010). 
II. ANALYSIS 
The Beneficiary is currently the Petitioner's director of research and development and previously held 
the positions of electronics design engineer and principal design engineer within the petitioning 
company. 
Because the Petitioner has not indicated or established that the Beneficiary has received a major, 
internationally recognized award, he must satisfy at least three of the ten criteria at 8 C.F.R. 
§ 204.5(h)(3)(i)-(x). In denying the petition, the Director found that the Beneficiary met only two 
criteria. On appeal, the Petitioner maintains that the Beneficiary meets at least two additional criteria. 
We have reviewed all of the evidence in the record, and conclude it does not support a finding that the 
Petitioner satisfies the requirements of at least three criteria. 
A. Evidentiary Criteria 
Evidence of the individual's membership in associations in the field for which 
class[fication is sought, which require outstanding achievements of their members, as 
judged by recognized national or international experts in their disciplines or fields. 8 
C.F.R. § 204.5(h)(3)(ii). 
The Petitioner submitted evidence that the Beneficiary was elevated to the grade of "senior member" 
in the Institute of Electrical and Electronics Engineers (IEEE) in July 2018, approximately six months 
2 
Matter of P-T- LLC 
after the filing of this petition. Therefore, this evidence cannot establish his eligibility at the time of 
filing and we will not farther address it. See 8 C.F.R. § 103.2(b)(l). A petition cannot be approved at 
a future date after the petitioner becomes eligible under a new set of facts. Matter of lzummi, 22 I&N 
Dec. 169, 175 (Comm'r 1998). That decision, citing Matter of Bardouille, 18 I&N Dec. 114 (BIA 
1981 ), farther provides that USCIS cannot "consider facts that come into being only subsequent to the 
filing of a petition." Id. at 176. 
The Petitioner also referenced evidence reflecting that the Beneficiary serves as the vice chair of the 
and member of the faculty selection committee for the electrical and 
~co_m_p_u-te_r_e_n_g-in_e_e_n __ n_g_d_e_p~artment ofthel I School of Mines and Technology. While these 
positions are notable, the Petitioner has not established that they equate to "membership in 
associations" in the field, or provided evidence that his membership on the advisory board or selection 
committee required outstanding achievements as judged by national or international experts in his 
field. 1 We agree with the Director's determination that this criterion has not been met. 
Evidence of the individual's participation, either individually or on a panel, as a judge 
of the work of others in the same or an allied field of spec[fication for which 
class[fication is sought. 8 C.F.R. § 204.5(h)(3)(iv). 
The Director found that the Petitioner submitted evidence satisfying this criterion. The record 
indicates that the Beneficiary has served as a peer reviewer of manuscripts for several IEEE journals 
and conferences. Accordingly, we agree with the Director's determination that he meets this criterion. 
Evidence of the individual's original scientific, scholarly, artistic, athletic, or business­
related contributions of major sign[ficance in the field. 8 C.F.R. § 204.5(h)(3)(v). 
The Petitioner contends that the Beneficiary's research and inventions have led to scientific, scholarly, 
and business-related contributions of major significance in his field. In order to satisfy the regulation 
at 8 C.F.R. § 204.5(h)(3)(v), a petitioner must establish not only that the individual beneficiary has 
made original contributions, it must also demonstrate that the contributions are of major significance 
in the field. For example, a petitioner may show that the contributions have been widely implemented 
throughout the field, have remarkably impacted or influenced the field, or have otherwise risen to a 
level of major significance. 
This regulatory criterion contains multiple evidentiary elements that the Petitioner must satisfy. It 
must demonstrate that the Beneficiary's contributions are original and scientific, scholarly, artistic, 
athletic, or business-related in nature. The contributions must have already been realized, rather than 
being prospective possibilities. It must also establish that the contributions rise to the level of major 
significance in the field as a whole, rather than to a project or to an organization. The phrase "major 
1 See USCTS Policy Memorandum PM 602-0005.1, Evaluation of Evidence Submitted with Certain Form I-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. (providing an example of admission to membership in 
the National Academy of Sciences as a Foreign Associate, which requires individuals to be nominated by an academy 
member, and membership is ultimately granted based upon recognition of the individual's distinguished achievements in 
original research). 
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Matter of P-T- LLC 
significance" is not superfluous and thus has meaning. See Silverman v. Eastrich Multiple Investor 
Fund, L.P., 51 F.3d 28, 31 (3d Cir. 1995), quoted in APWU v. Potter, 343 F.3d 619, 626 (2d Cir. 
2003). "Contributions of major significance" connotes that the petitioner's work has significantly 
impacted the field. See Visinscaia, 4 F. Supp. 3d at 134. 
The Petitioner claims that the Beneficiary "has solved previously intractable problems in the fields of 
.__ ______ ___. and electrical engineering . . . to the widespread acclaim of and use by his 
colleagues, domestically and abroad." In addition, the Petitioner asserts that he has "produced novel 
commercial products with substantial benefits above and beyond the product lines theretofore 
available in his field." The Petitioner contends that the Director was dismissive of the submitted 
opinion letters and the significance of the Beneficiary's research and inventions. 
The Petitioner submitted: evidence that it has two U.S. patents and one pending patent application 
which name the Beneficiary as a co-inventor; several letters from professors, researchers, and clients 
who are familiar with the Beneficiary's work; and citation data for the Beneficiary's published articles. 
On appeal, the Petitioner asserts that the expert opinion letters amply demonstrate the Beneficiary's 
qualification under this criterion, and maintains that the Beneficiary has shown that his work has 
positively affected not only "his employer (substantially) and its customers and its customers' 
customers, but also numerous academic entities and dozens of colleague researchers domestically and 
abroad." 
Regarding the letters from the professors and researchers in the record, an agency "may, in its 
discretion, use as advisory opinions statements ... submitted in evidence as expert testimony," but it 
is ultimately responsible for making the final determination regarding an individual's eligibility for 
the benefit sought. Matter o_fCaron Int'l, Inc., 19 I&N Dec. 791, 795 (Comm'r 1988). 
The Petitioner submitted a letter from its CEO, who described the '------------~ Beneficiary's "notable scientific achievements," and specifying that he has contributed to the 
development of more than 80 commercial products that are used in oil and gas production, irrigation, 
solar, and wind renewable energy. He highlights three products in particular, explaining that the 
Beneficiar is co-inventor of the com an 's ' that 
reduces 
input line harmonics ... and maintains constant DC voltage on the bus ca acitator." 
describes the product as "the onlyl I low harmonic,'----------~ in the 
world," and states that it has been widely ada ted in industries such as wind ower and a ricultural 
irrigation," noting that previously there was .__ ___________ ='""T"" ________ ___., 
'--------~~--~__." He also notes that this product is the only.__ ________ _ 
that complies with the IEEE 519 that is increasingly used by U.S. electric utilities. Finally, 
I !explained that the product was "widely discussed and reviewed by Electronic Power 
Research Institute (EPRI) magazine as a major advancement in solutions for pumping water in rural 
areas"2 and that it has generated more than $8 million in revenue to date. 
,--....!...!.!."'--'--><.>.!.""""'-'......._~"'-'-'-!.=,..___.._._ __ ___........,_,c..i..:r......c...,..,___,_""""".L.Ll.J"""""CL......!..""""""'-'--'"'-"';blished by EPRT and titled~! ____ ___. 
'------------------.------------'--In_t_hi_,s publication, EPRI reported on the 
~rmance characteristics of the Petitioner's.__ __________ ___,. This does not appear to be the same 
L_Jproduct discussed inl Is letter as that product was patented in 2015. 
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Matter of P-T- LLC 
farther states that the Beneficiary designed a patented "revolution'1a,nJ____,.........__l---.---~ 
--~-it_h_a_u~xiliary power supply" which resulted in development of a series of LJfor the .... I _ ___, 
irrigation market, resulted in $2 million in sales in 201 7, and directly led to the addition of 15 
~n-ew____.employees. In addition, he highlights a newly launched, patent-pending 'I I 
[ I that will I I into a balance! I I I with voltage unbalance as low as 1 %." He describes this as a "ma·or advancement in 
'------,--,----,-----,-----,--....,....... 
," and the first and only in the world. The 
Petitioner also submitted a letter from its previous chief technolo officer who 
highlights the Beneficiary's work on the Petitioner's.__ _________ ____. noting that "this 
solution has eluded workers in the field for many years, and is quite a breakthrough." 
A letter from the Petitioner's customerJ I Director ofl ~ater Management,~ 
that he is acquainted with the Beneficiary's work through visits to the Petitioner and through thel__J 
and I ~ products that are based on the Beneficiary's research.I l indicates that 
he has found these to be "unique and technologically advanced products" and believes that "they 
represent si nificant advances i_,_ _____________ ____. He discusses the complexity 
of irri ation and pumping systems and the challenges of lpera
1
ing them in rural 
environments. ,__ ___ _, also highlights that no other company provides a that complies with 
the IEEE 519 standard enforced by some electric µtilitifs, and states that some of his company's 
customers could not otherwise benefit from using al__Jin their farming operations. He concludes 
that the Beneficiary's research is "critical to the advancement of agricultural irrigation solutions in the 
United States." 
The Petitioner also provided a letter from I I, professor of electrical and computer 
engineering at thel !school of Mines & Technology. I I states that he is familiar 
with the Petitioner "as an innovative company" and with the Beneficiary, noting that he has "impressed 
with his contributions to his company and to the electronics industry at large." He notes that the 
Beneficiary's research has led to "groundbreaking solutions for the cost-effective 
I------~----' 
to feed power from unconventional energy sources, such as wind and solar, to the power 
grid." I I also notes the Beneficiary's work on the .__ ______________ _, 
calling the Petitioner's products a "significant advance in the state of the art for this type of product." 
While these letters establish that the Beneficiary's research and development work with the petitioning 
company is original, the expert opinion evidence does not explain how the work has already 
significantly impacted the field. The Petitioner must demonstrate that the Beneficiary's contributions 
rise to the level of major significance in the field as a whole, rather than to an organization. While 
there appears to be agreement that the research he has performed has the potential for wide application, 
the Petitioner has not submitted evidence that the Beneficiary's original contributions were considered 
to be of major significance in the field as of the date of filing. Notably, whilel I stated that 
the Beneficiary is able to "convert research results into commercialized products that revolutionize 
industries and affect the quality of lives all over the world" he does not elaborate as to how the 
Beneficiary's work in the development ofl I has already resulted in this type of major 
impact. Instead, he goes on to state that the Beneficiary's "inventions and research have had a 
profound jmpact on the development of [the Petitioner] and on the manufacturing economy of a small 
town likel ~, 
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Matter of P-T- LLC 
The Petitioner also submitted letters from two individuals who state that they rely on the Beneficiary's 
published research inl lin their own work. I I a Team Scientific 
Coordinator at thel I in the Netherlands. states that he cited the Beneficiarv's 
2009 paper 1 
I in his "papers and research." He explains thatl 
1----.,..---------' '------------~ 
I requires the solving of complicated partial differential equations that can only be solved with 
'---~ 
approximation methods, and indicates that the Beneficiary "developed a novel approximation 
technique to solve these equations and successfully applied such techniques to industrial applications." 
He notes that the referenced paper "has already been cited by more than 40 researchers from various 
countries across the globe3i many have replicated his results and used his published research to their 
research and publications."[ !describes the Beneficiary's work o~ I as 
an "extremely significant contribution to our field." 
Similarly, I I assistant professor of robotics and mechatronics atl !university 
in Kazakhstan, states that he has not worked with the Beneficiary but knows of his research on 
I land has cited his work l I 
I I' I I explains that the Beneficiary was "the first person to successfully 
implement the I lbased algorithms td .... I" and adds 
that "many researchers around the world have taken an interest in these techniques due to fast 
stabilization, a wide operating range, and good dynamic performance." He indicates that the citations 
to the Beneficiary's research "have led to international interest in applying his results to new research." 
While bot~ I and I !describe the Beneficiary's research iq I as novel or 
original, neither provided a sufficient explanation to support a conclusion that the work represented a 
major contribution in the field, and neither articulated how they or other researchers have been 
influenced by the Beneficiary's novel techniques in this area. The fact that the Petitioner has 
published articles that other researchers have referenced is not, by itself: indicative of a contribution 
of major significance. Publications are not sufficient under 8 C.F.R. § 204.5(h)(3)(v) absent evidence 
that they were of "major significance." See Kazarian v. USCIS, 580 F.3d 1030, 1036 (9th Cir. 2009), 
affd in part, 596 F.3d 1115 .. 
Finally, the Petitioner submitted letters from two scientists who su ervised the Beneficiary's work 
wh · · fr"l"'-'-'-'L--~---....1, a retired senior scientist from 
the m India who supervised the Beneficiary's 
master's degree research completed at L----,-------'--"'J..LLJ.i....i..J..1.JLu..,the Beneficiary made "an 
ori inal and substantial contribution to the field of through developing new 
~----r-----r-------------~ '--------____.ummarized the Beneficiary's work 
on an lrojectf and described it as "pioneering work" that "has been used by the researchers and 
engineers at ' He also describes the Beneficiary's work in I I 
I I with the Petitioner and concludes that the Beneficiary "has substantially contributed to the 
development of advanced power electrics and controls for industrial applications." 
3 The Petitioner submitted evidence that the Beneficiary's article titled~----------------' 
, , I bas been cited by 15 other researchers since its publication in 
2009; the Beneficiary reported 41 total citations to his entire body of published work. 
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Matter of P-T- LLC 
'i=====r------.===l'-'E=-m=e;.:..;ritus Professor of Electrical & Computer Engineering at the I I 
.__ _ ___.IUniversity,I I also provided a letter in support of the petition~ I who 
advised the Beneficiary on his doctoral dissertation, states that "the contributions he has made in the 
development of.__ _________________ --,-__ ,______.are exemplary and have 
resulted in prolific applications in the industrial electronics an .___~ industries" and have "greatly 
impacted [ the Petitioner] and agricultural irrigation." 
Letters that specifically articulate how an individual's contributions are of major significance to the 
field and its impact on subsequent work add value, however, letters that lack specifics do not add value 
and are not considered to be probative evidence that may form the basis for meeting this criterion. 4 
While these letters describe with some specificity how the Beneficiary has made original contributions 
to innovative products developed by the Petitioner, the record does not sufficiently detail how the 
Beneficiary's research has been implemented outside of the Petitioner's and its customers' businesses, 
or indicate how the Beneficiary's inventions have already significantly and demonstrably impacted 
the field. The record does not contain, for example, detailed explanations or inde:endent evidence of 
the "prolific applications" of the Beneficiary's research mentioned byl I 
As noted, the Beneficiary has been listed as a co-inventor on two U.S. patents and had a third pending 
patent application when the petition was filed. A patent recognizes the originality of the idea, but it 
does not by itself demonstrate that the inventor made a contribution of major significance in the field. 
Rather, the significance of the innovation must be determined on a case-by-case basis. While several 
of the submitted letters addressed the significance of the products co-invented by the Beneficiary, the 
supporting letters, for the reasons already discussed, are lacking an explanation as to how these 
products have made an impact of major significance in the field. 
Finally, the record also contains information from Google Scholar listing the number of citations for 
each of the Beneficiary's five publications. The Petitioner has not established that the documented 
citation rate ( demonstrates that the Beneficiary's work has been widely implemented in the field or 
that it has had a major influence. The Petitioner has not provided, for example, information that 
compares the Beneficiary's citations to other similarly, highly cited articles that the field views as 
having been of major significance. Although these citations show that the Beneficiary's research has 
received attention from the field, the Petitioner has not shown that the number of citations to his 
individual papers is indicative of significant influence in the field. 
For the reasons discussed above, the Petitioner has not established that the Beneficiary has made 
original scientific contributions of major significance in the field. 
Evidence of the individual'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 Director determined that the Petitioner submitted evidence demonstrating that the Beneficiary 
meets this criterion. The record reflects that the Beneficiary authored scholarly articles published by 
4 See 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 ADI 1-14 6 (Dec. 22, 2010), 
https://www.uscis.gov/policymanual/HTML/PolicyManual.html. 
7 
Matter of P-T-LLC 
the American Control Conference, North American Power Symposium, and Cm?ference on 
Computational Intelligence and Multimedia Applications. Thus, the Petitioner has established that the 
Beneficiary meets this criterion. 
Evidence that the individual has performed in a leading or critical role for 
organizations or establishments that have a distinguished reputation. 8 C.F.R. § 
204.5(h)(3)(viii). 
The Director determined that the record contained evidence that the Beneficiary performs in a leading 
or critical role for the Petitioner. However, the Director found that the Beneficiary did not meet this 
criterion because the Petitioner did not provide evidence establishing its distinguished reputation. 
We agree that the Petitioner submitted sufficient evidence of the Beneficiary's critical role in its 
organization as its principal design engineer and director of research and technology. In a request for 
evidence (RFE), the Director advised the Petitioner that it would need to provide evidence of its 
distinguished reputation in order to establish that the Beneficiary meets this criterion. 
The Petitioner responded as follows: 
[The Petitioner] operates in a niche market and does not generally itself receive press 
coverage. Nevertheless, it is recognized as a leader in its field resulting in, inter alia, 
reviews by the Electric Power Research Institute, the leading public interest research 
organization in its field ... ; the recommendation of its products by major international 
manufacturers ... ; and the acclaim of his colleagues in their references. 
As noted the Petitioner rovided a co of EPRI's I I 2014 P Techwatch report on 
The report 
provides an overview of the types of products available to serve~-~-~ agricultural equipment in 
rural areas that receive onlyl I electrical supply. The Petitioner's I O I I lis discussed in the report's section on'.__ ___________ ___. and the EPRI 
notes the positive results of its own laboratory evaluation of the product. The Petitioner did not provide 
any additional information regarding EPRI or its publications and has not shown that inclusion of one 
of its products in this overview of available! I solutions is indicative of the company's 
distinguished reputation. 
The Petitioner also provided a "Site Preparation Guide" for thel I Printer. The guide 
advises the user that the printer requires! I power, and states that the Petitioner's I I 
I I is "the recommended I, I for the printer." On appeal, 
the Petitioner also submits marketing reports reflecting that Dis the leading supplier of large format 
printers. The Petitioner maintains that ~ recommendation of its I [vroduct is 
indicative of its distinguished reputation. In addition, the Petitioner reference~ I J's support 
letter, noting that it demonstrates that the company "has received recognition within its indu_~ and 
throu h use by other emineT orgalizations." The Petitioner's reliance on the reputations oiLJ and 
Lr--,___....1 s organization Water Management, described as a startup business unit within 
.__ _ __.Irrigation), is not sufficient to establish its own distinguished reputation in the field. 
8 
Matter of P-T- LLC 
The Petitioner also submitted its own marketing materials, which indicate that the company was 
founded in 1999 and "is recognized as a world leader id._ _____ ____.~echnologies" but this claim 
is insufficient to meet its burden absent corroborating evidence of its reputation in the industry. 
Finally, the Petitioner states that it "has established that it is a distinguished organization because of 
its market position, commercial successes, and reputation." However, the record does not contain 
independent evidence that would enable us to compare the Petitioner's market position, commercial 
success and reputation to that of its competitors in the industry. Accordingly, the Petitioner has not 
established that the Beneficiary meets this criterion. 
B. Summary 
The Beneficiary is not eligible because the Petitioner has not submitted the required initial evidence 
of either a qualifying one-time achievement or documents that meet at least three of the ten criteria 
listed at 8 C.F.R. § 204.5(h)(3)(i)-(x). Thus, we do not need to folly address the totality of the 
materials in a final merits determination. Kazarian, 596 F.3d at 119-20. Nevertheless, we advise that 
we have reviewed the record in the aggregate, and conclude that it does not support a finding that the 
Beneficiary has established the level of expertise required for the classification sought. 
The Petitioner seeks a highly restrictive visa classification, intended for individuals already at the top 
of their respective fields, rather than for individuals progressing toward the top. USCIS has long held 
that even athletes performing at the major league level do not automatically meet the "extraordinary 
ability" standard. Matter of Price, 20 I&N Dec. 953, 954 (Assoc. Comm'r 1994). Here, the Petitioner 
has not shown that the significance of the Beneficiary's scientific and business-related 
accomplishments is indicative of the required sustained national or international acclaim or that it is 
consistent with a "career of acclaimed work in the field" as contemplated by Congress. H.R. Rep. No. 
101-723, 59 (Sept. 19, 1990); see also section 203(b )(l)(A) of the Act. Moreover, the record does not 
otherwise demonstrate that the Beneficiary has garnered national or international acclaim in the field, 
and he is one of the small percentage who has risen to the very top of the field of endeavor. See section 
203(b)(l)(A) of the Act and 8 C.F.R. § 204.5(h)(2). 
III. CONCLUSION 
The Petitioner has not shown that the Beneficiary qualifies for classification as an individual of 
extraordinary ability under section 203(b )(1 )(A) of the Act. The appeal will be dismissed for the above 
stated reasons. In visa petition proceedings, it is the petitioner's burden to establish eligibility for the 
immigration benefit sought. Section 291 of the Act, 8 U.S.C. § 1361; Matter ofSkirball Cultural Ctr., 
25 I&N Dec. 799, 806 (AAO 2012). Here, that burden has not been met. 
ORDER: The appeal is dismissed. 
Cite as Matter of P-T-LLC, ID# 5214358 (AAO Oct. 21, 2019) 
9