dismissed EB-1A Case: Software Engineering

MATTER OF C-M-C-
APPEAL OF TEXAS SERVICE CENTER DECISION 
Non-Precedent Decision of the 
Administrative Appeals Office 
DATE: NOV. 22,2016 
PETITION: FORM I-140, IMMIGRANT PETITION FOR ALIEN WORKER 
The Petitioner, a software engmeermg director, 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 classification makes visas available to foreign 
nationals 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, Texas Service Center, denied the petition, concluding that the Petitioner had not 
provided documentation satisfying the initial evidence requirements set forth at 8 C.F.R 
§ 204.5(h)(3), which requires documentation of a one-time achievement or evidence that meets at 
least three of the ten regulatory criteria. 
We initially summarily dismissed the Petitioner's appeal but subsequently reopened the matter. The 
Petitioner submits additional documentation and a brief stating that he meets more than three 
criteria. 
Upon de novo review, we will dismiss the appeal. 
I. LAW 
The Petitioner may demonstrate his extraordinary ability through sustained national or international 
acclaim and achievements that have been recognized in her field through extensive documentation. 
Specifically, section 203(b)(l)(A) of the Act states: 
Aliens with extraordinary ability. -- An alien is described in this subparagraph 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, 
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(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 sustained 
acclaim and the recognition of his achievements in the field through a one-time achievement (that is a 
major, internationally recognized award). If he does not submit this documentation, then he must 
provide sufficient qualifying evidence that meets at least three of the ten criteria listed at 8 C.F.R. 
§ 204.5(h)(3)(i)-(x). 
Satisfaction of at least three criteria, however, does not, in and of itself, establish eligibility for this 
classification. 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. USCJS, 772 F. Supp. 2d 1339 (W.D. Wash. 2011), aff'd, 683 
F.3d. 1030 (9th Cir. 2012); Matter ofChawathe, 25 I&N Dec. 369, 376 (AAO 2010) (holding that 
the "truth is to be determined not by the quantity of evidence alone but by its quality" and that U.S. 
Citizenship and Immigration Services (USCIS) examines "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"). Accordingly, where a 
petitioner submits qualifying evidence under at least three criteria, we will determine whether the 
totality of 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. 
II. ANALYSIS 
The Petitioner currently works as director of engineering for an online 
education company. The Petitioner filed Form 1-140, Immigrant Petition for Alien Worker, along 
with supporting documentation seeking to classify himself as an individual of "extraordinary ability 
in the field of software engineering, particularly scalable web architectures." The Director found 
that the Petitioner met the judging criterion under 8. C.F.R. § 204.5(h)(3)(iv) and the leading or 
critical role criterion under 8 C.F.R. § 204.5(h)(3)(viii), but had not satisfied any of the other criteria 
at 8 C.F.R. § 204.5(h)(3). On appeal, the Petitioner maintains that he meets the awards criterion 
under 8 C.F.R. § 204.5(h)(3)(i), the published material criterion under 8 C.F.R. § 204.5(h)(3)(iii), the 
original contributions criterion under 8 C.F.R. §· 204.5(h)(3)(v), the authorship of scholarly articles 
criterion under 8 C.F.R. § 204.5(h)(3)(vi), and the high salary criterion under 8 C.F.R. 
§ 204.5(h)(3)(ix). We have reviewed the entire record of proceedings, and it does not support a 
finding that the Petitioner meets the plain language requirements of at least three criteria. 
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A. Evidentiary Criteria 
As the Petitioner has not established that he has received a major, internationally recognized award, 
he must satisfy at least three of the alternate regulatory criteria at 8 C.F.R. § 204.5(h)(3)(i)-(x). 
Documentation of the alien 's receipt of lesser nationally or internationally 
recognized prizes or awards for excellence in the field of endeavor. 8 C.F.R. 
§ 204.5(h)(3)(i). 
The Petitioner submitted a letter from of 
India, discussing the Petitioner's prior employment "in a 
senior engineering capacity at · as a member of its "Workflows team." 
claimed that the Petitioner "was presented with which was 
given to only three of the company's thousands of employees worldwide, and which came with a 
significant cash award." The Petitioner, however, did not provide a copy of his 
or any payroll documentation reflecting his receipt of the cash award. 
statement, unsubstantiated by supporting evidence, is insufficient to satisfy the 
Petitioner's burden ofproof. Matter o.fSoffici, 22 I&N Dec. 158, 165 (Comm'r 1998) (citing Matter 
o.fTreasure Craft ofCalffornia, 14 I&N Dec. 190 (Reg'l Comm'r 1972)). Nonetheless, even if the 
Petitioner documented his performance award from the record does not demonstrate 
that this award is recognized on a national or international level. 
The Petitioner also provided evidence of his 
physics examinations that he took in India. 
rankings from various science, mathematics, and 
His documentation included a letter from the 
entrance examination score for those seeking admission to the 
applicants in India. In addition, he submitted a ' 
indicating that his 1996 
ranked him among the 
certificate stating that he "took part in the [ 
] examination held in January 1995 in 
category and ranked out of 2,101 students in that category. Furthermore, the Petitioner 
offered a recruiting letter from and a printout of the 
examination results for September 1995 reflecting that he 
ranked on the list of those seeking admission to the He also provided a 
certificate from the indicating that he "placed among 
the Top in Part A" of the (1995) "out of 
candidates" enrolled at Additionally, the Petitioner 
submitted a ' in recognition of his "very good performance in the 
in 1993. 
On appeal, the Petitioner argues that the Director did not properly consider "a statement from a top 
official in the Indian government confirming that [the Petitioner] received five awards that are 
considered national in nature." The record included a letter from private secretary to 
discussing the above Indian examinations. In his letter, explained 
the process for each of the five examinations and stated that the Petitioner's aforementioned rankings 
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constitute "awards" which are "recognized as being national in scope." USCIS, however, need not 
rely on unsubstantiated statements. See 1756, Inc. v. US. Att y Gen., 745 F. Supp. 9, 15 (D.D.C. 
1990) (holding that an agency need not credit conclusory assertions in immigration benefits 
adjudications). 
The plain language of this criterion requires the Petitioner 's receipt of "nationally or internationally 
recognized prizes or awards for excellence in the field endeavor." In this case, the Petitioner's "field 
of endeavor" is software engineering, and none of the examination results he offered were for 
excellence in that particular field. Furthermore, with respect to the certificate from the . it 
reflected his placement in the top out of students enrolled at 
Accordingly, the certificate reflects institutional or local recognition at the 
Petitioner's school rather than a nationally recognized award for excellence in the field. Similarly, 
the Petitioner's for his "very good performance in the 
constitutes regional recognition in a student mathematics competition, and 
not a nationally or internationally recognized award in his field. Regarding the Petitioner's ranking 
of among the applicants in India, his ' 
ranking of out of 2,1 01 students in category and his ranking of on the 
list of those seeking admission to the the Petitioner has not shown that such 
examination results equate to "nationally or internationally recognized prizes or awards for 
excellence" in the field of software engineering. For the aforementioned reasons, the Petitioner has 
not established that he meets this regulatory criterion. 
Published material about the alien in professional or major trade publications or other 
major media, relating to the alien 's work in the field for which classffication is sought. 
Such evidence shall include the title, date, and author of the material, and any necessary 
translation. 8 C.F.R. § 204.5(h)(3)(iii). 
The Director found that the Petitioner did not meet this criterion because the submitted articles were 
not about him. The Petitioner provided various online articles about and 
and their service offerings and systems' features, but none of the articles mentioned the Petitioner. 
The plain language of the regulatory criterion requires "published material about the alien." Articles 
that are not about the Petitioner do not meet this regulatory criterion . See, e.g., Negro-Plumpe v. 
Okin, 2:0'?-CV-00820 at *1, *7 (D. Nev. Sept. 2008) (upholding a finding that articles about a show 
are not about the actor). On appeal, the Petitioner lists this criterion among the seven criteria he 
previously claimed to satisfy, but he does not address the Director's findings for this criterion or 
offer any further arguments or documentary evidence. Accordingly, the Petitioner has not 
established that he meets this regulatory criterion. 
Evidence of the alien 's participation, either individually or on a panel, as a judge of 
the work of others in the· same or an allied field of specification for which 
classification is sought. 8 C.F.R. § 204.5(h)(3)(iv). 
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The Petitioner submitted evidence reflecting that he reviewed nominations and selected winners for 
the As such, the Director found 
that the Petitioner met this criterion, and we concur with that determination. 
Evidence of the alien 's original scient?fic, scholarly, artistic, athletic, or business­
related contributions of major sign?ficance in the field. 8 C.F.R. § 204.5(h)(3)(v). 
As evidence under this criterion, the Petitioner provided several reference letters. The Director 
considered the letters and concluded that although they discussed the background and achievements 
of the Petitioner, they were insufficient to establish that his work constitutes original contributions of 
major significance in the field. The Director noted that the Petitioner had not shown that his work 
has made a significant impact beyond the company he works for and the clients it serves. 
On appeal, the Petitioner does not point to any specific software engineering contributions that meet 
the requirements of this regulatory criterion. Instead, the Petitioner argues that "the evidence 
presented clearly demonstrates that by having a significant impact on [his] employer, his work by 
extension has had an impact on his field, and is therefore of major significance." The Petitioner 
further contends that there is no regulatory requirement stating "that a particular field must be 
changed as result of an individual's original contributions in order for those contributions to be of 
major significance." 
The Petitioner offered letters of support discussing his work on software engineering projects for his 
employers and their clients.' For example, chief executive officer (CEO) at 
stated: "[The Petitioner's] impact on was instantaneous. He can build 
infrastructure and back-end technologies , but he is also proficient in front-end development . 
. . . He 
made our video content social-media-enabled and created our integration- within 
the span of a single week." did not explain how the Petitioner's work has affected 
the field beyond and it clients or has otherwise risen to the level of scientific or 
business-related contributions of major significance in the software engineering field. The plain 
language of the regulation requires that the Petitioner 's contributions be "of major significance in the 
field" rather than just to his employer and its customers. 
CEO of indicated that the Petitioner created "a distributed folder feature that 
allows users to work on different versions of a document in a common folder." In addition, 
noted that that Petitioner developed "a web conferencing tool that allows users to host and 
attend online meetings where they can share desktops, as well as text-chat and video-chat with up to 
10 concurrent users," but he did not provide examples of how the distributed folder feature and web 
conferencing tool have influenced the field of software engineering or how they otherwise equate to 
original contributions of major significance in the field. 
1 We discuss only a sampling of these letters, but have reviewed and considered each one. 
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a director at mentioned that the Petitioner worked on a 
project to ensure that different versions of the company's database product could communicate with 
each other. stated that the Petitioner's contributions to the project included 
"using object-oriented to run regression suites," "testing the transportation of troublespaces in 
our 1 Oi database across different platforms," and "developing an 
framework] in Java for testing interoperability between different versions of our databases on 
different platforms." While discussed the Petitioner's database communication 
project for the record does not include documentary evidence indicating his work has 
substantially impacted the field or otherwise constitutes original contributions of major significance 
in the field of software engineering. 
an editorial manager at noted that the Petitioner and his team revamped 
proprietary and that the company's enhanced 
allows it to "create, update, and release content on a massive scale __:_hundreds of lessons every 
month." did not offer examples of how the system has affected the software 
engineering field in a substantial way or has otherwise risen to the level of an original contribution 
of major significance in the field. 
Vice President of Career Development and a Broker Associate at 
indicated that his company is a client of 
and relies on its training products. noted that the Petitioner "created an automated 
framework to submit content daily in an organized manner in the forms of Text, XML, and 
Video Sitemaps, thus making it easy for search engines to classify, rank, and present these pages to 
Internet users." The record, however, does not include supporting evidence showing that the 
Petitioner's automated framework equates to a contribution of major significance in the software 
engineering field. 
director of learning and development at an operator of upscale fitness 
clubs, stated that his company's training platform is powered by the 
that the Petitioner developed at further mentioned that "[t]he 
has helped create around 50 training materials" for its employees, but did not explain 
how the has widely impacted the field of software engineering, so as to demonstrate original 
contributions of major significance in the field. 
chief technology officer of noted that his company's suite of 
training services for entrepreneurs "would not be possible with a training platform that was built by 
added that the Petitioner created a single sign on (SSO) feature for 
customers that allowed them "to seamlessly login to and be led to the right training 
that is assigned to them." While the training platform and SSO feature devised by the Petitioner are 
useful to there is no indication that they have affected his field at a level indicative of 
original scientific contributions of major significance in software engineering. 
The Petitioner submitted letters of varying probative value. We have addressed the specific 
affirmations above. Generalized conclusory statements that do not identifY specific contributions or 
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their impact in the field have little probative value. See 1756, Inc., 745 F. Supp. at 15. In addition, 
uncorroborated statements are insufficient. See Visinscaia, 4 F.Supp.3d at 134-35; Matter ofCaron 
Int'l, Inc., 19 I&N Dec. 791, 795 (Comm'r 1988) (holding that an agency "may, in its discretion, use 
as advisory opinions statements ... submitted in evidence as expert testimony," but is ultimately 
responsible for making the final determination regarding an alien's eligibility for the benefit sought 
and "is not required to accept or may give less weight" to evidence that is "in any way 
questionable"). The submission of reference letters supporting the petition is not presumptive 
evidence of eligibility; USCIS may evaluate the content of those letters as to whether they support 
the petitioner's eligibility. !d. See also Matter of V-K-, 24 I&N Dec. 500, n.2 (BIA 2008) (noting 
that expert opinion testimony does not purport to be evidence as to "fact"). Without additional, 
specific evidence showing that his work has been unusually influential, has substantially impacted 
the software engineering field, or has otherwise risen to the level of original contributions of major 
significance in the field, the Petitioner has not established that he meets this regulatory 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 Petitioner submitted a blog post available at entitled 
which promoted and its online content. The Director found that 
the Petitioner did not meet this criterion because the blog post was not scholarly. Furthermore, the 
evidence did not show that the blog post appeared in professional or major trade publications or 
other major media. On appeal, although the Petitioner lists this criterion among the seven criteria he 
previously claimed to satisfy, he does not challenge the Director's findings for this criterion or 
provide any additional arguments or evidence. Therefore, the Petitioner has not established that he 
meets this regulatory criterion. 
Evidence that the alien 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 Petitioner's documentation reflected that he, as director of 
engineering, performed in a leading or critical role for an organization that has a 
distinguished reputation. The record supports the Director's finding that the Petitioner meets this 
regulatory criterion. 
Evidence that the alien has commanded a high salary or other signfficantly high 
remuneration for services, in relation to others in the.field. 8 C.F.R. § 204.5(h)(3)(ix). 
With respect to his compensation, the Petitioner provided a May 2015 letter from 
stating that he "is paid $12o;ooO/year" and has been granted "stock options that are 
currently valued at over $150,000." On appeal, the Petitioner submits a December 2015 letter from 
a partner with a global venture capital firm, contending that the 
Petitioner "has been compensated at an exceptionally high rate for someone at his level 
when 
compared to the standards in the field of software engineering." further indicates: 
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As is often the case with early employees of startup companies in the high-tech field, 
[the Petitioner] has been granted a considerable amount of stock options. To be 
specific, he was the recipient of 150,000 shares in 2011. As ofmid-2014, 131,250 of 
those shares had vested, and their fair market value was $131,651.88. 
In addition, notes that the Petitioner was "granted an additional 10,000 shares in late 
2014." We note that the Petitioner received the additional10,000 shares after he filed the Form I-140 
on June 1, 2014. Eligibility, however, must be established at the time of filing. 8 C.F .R. § 103 .2(b )(1 ), 
(12); Matter of Katigbak, 14 I&N Dec. 45, 49 (Reg'l Comm'r 1971). Accordingly, we cannot 
consider any remuneration received after the date the petition was filed as evidence to establish the 
Petitioner's eligibility at the time of filing. 
Regarding the aforementioned references' attestations concerning Petitioner's compensation from 
he did not provide any supporting evidence in the form of payroll records, 
employee benefits statements, or income tax forms. See Matter of Sofjici, 22 I&N Dec. at 1 65. The 
Director's decision noted that although USCIS issued a request for evidence (RFE) instructing the 
Petitioner to submit his W-2 Forms, he did not submit the requested documents. 
Nevertheless, even if the Petitioner provided sufficient evidence of his compensation from 
the record does not show that he has received a high salary or other significantly high 
remuneration for services, in relation to others in the field. As evidence of his high salary relative to 
others in the field, the Petitioner's response to the RFE included pay information from the U.S. 
Bureau of Labor Statistics (BLS) indicating that "[t]he median annual wage for applications software 
developers was $90,060 in May 2012"2 and that "the top 10 percent earned more than $138,880." 
Because the Petitioner's yearly salary of $120,000 falls substantially below that of the top ten 
percent of software engineers, the wage information from the BLS does not show that he has earned 
a high salary relative to others in the field. 
In support of the appeal, the Petitioner provides a December 2015 letter from 
president of stating that he reviewed the " 
data for software engineers and that he believes the Petitioner "ranks in the top 
10% nationally." Based on his review of"the 75th percentile of 'Total Direct Compensation (TDC) 
Actual' data found on pages 64 and 70 of the survey," concluded that the Petitioner's 
pay as a software engineer is "above the maximum of the U.S. range (page 64) and at the 87th 
percentile of the West Coast sample (page 70)." While the appellate submission contains a copy of 
the it does not include pages 64 and 70 to support 
claims. See Matter ofSoffici, 22 I&N Dec. at 165. Regardless, the 75th percentile of 
software engineers' compensation is not an appropriate basis for comparison as the Petitioner is a 
director of engineering and serves in a managerial capacity. 
2 According to the BLS, "[t]he median wage is the wage at which half the workers in an occupation earned more than 
that amount and half earned less." 
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The Director's decision noted that "the Petitioner is not just a software developer, but rather he is the 
Director of Engineering for which is a higher level than a regular software developer." On 
appeal, the Petitioner contends that the Director's "statement is nonsensical" and that requiring "an 
individual's compensation be compared to other elite members of that field rather than to average 
members of the field is to render [this] regulatory criterion meaningless." The Director, however, 
did not state that the Petitioner's compensation should be compared to other "elite members" of his 
field. Rather, the Director indicated that the Petitioner's managerial position for 
reflects a "higher level" of duties and responsibilities than those of a software engineer. The 
Petitioner must present evidence showing that has earned a high salary or significantly high 
remuneration in comparison with those performing similar services in the field. See Matter ofPrice, 
20 I&N Dec. 953, 954 (Assoc. Comm'r 1994) (considering a professional golfer's earnings versus 
other PGA Tour golfers); see also Skokos v. US. Dept. of Homeland Sec., 420 F. App'x 712, 713-14 
(9th Cir. 2011) (finding average salary information for those performing lesser duties is not a 
comparison to others in the field); Grimson v. INS, 934 F. Supp. 965, 968 (N.D. Ill. 1996) 
(considering NHL enforcer's salary versus other NHL enforcers); Muni v. INS, 891 F. Supp. 440, 
444-45 (N. D. Ill. 1995) (comparing salary of NHL defensive player to salary of other NHL 
defensemen). Accordingly, the compensation data offered for software engineers does not constitute 
an appropriate basis for comparison. 
Lastly, the Petitioner did not provide evidence showing that his stock options reflected significantly 
high remuneration compared to others in his field. In his letter, specifically noted that 
receiving a considerable amount of stock options "is often the case with early employees of startup 
companies in the high-tech field." 
In this case, the Petitioner has not established that he has received a high salary or other significantly 
high remuneration for services in relation to others in the field. Therefore, the Petitioner has not 
established that he meets this regulatory criterion. 
B. Summary 
As explained above, the evidence provided satisfies only two of the regulatory criteria. As a result, 
the Petitioner has not submitted the required initial evidence of either a 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). 
Had the Petitioner included the requisite material under at least three evidentiary categories, our next 
step of analysis would be a final merits determination that considers all of the submissions in the 
context of whether he has achieved: ( 1) a "level of expertise indicating that [he] is one of that small 
percentage who have risen to the very top of the field of endeavor," and (2) "that the [petitioner] has 
sustained national or international acclaim" and that his "achievements have been recognized in the 
field of expertise." 8 C.F.R. § 204.5(h)(2), (3); see also Kazarian, 596 F.3d at 1119-20. As the 
Petitioner has not done so, the proper conclusion is that he has not satisfied the antecedent regulatory 
requirement of presenting initial evidence set forth at 8 C.F.R. § 204.5(h)(3)(i)-(x). See Kazarian, 
596 F.3d at 1122. Nevertheless, although we need not provide the type of final merits determination 
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referenced in Kazarian, a review of the record in the aggregate does not support a finding that the 
Petitioner has achieved the level of expertise required for this classification. 
C. 0-1 Nonimmigrant Status 
We note the record of proceedings reflects that the Petitioner received 0-1 status, a classification 
reserved for nonimmigrants of extraordinary ability. Although USCIS has approved at least one 0-1 
nonimmigrant visa petition filed on behalf of the Petitioner, the prior approval does not preclude 
USCIS from denying an immigrant visa petition which is adjudicated based on different standard­
statute, regulations, and case law. Many Form 1-140 immigrant petitions are denied after USCIS 
approves prior nonimmigrant petitions. See, e.g, Q Data Consulting, Inc. v. INS, 293 F. Supp. 2d 25 
(D.D.C. 2003); IKEA US v. US Dept. of Justice, 48 F. Supp. 2d 22 (D.D.C. 1999); Fedin Brothers 
Co. Ltd., 724 F. Supp. at 1103. Furthermore, our authority over a USCIS service center, the office 
responsible for adjudicating the nonimmigrant visa petition, is comparable to the relationship 
between a court of appeals and a district court. Even if a service center director has approved a 
nonimmigrant petition on behalf of an individual, we are not bound to follow that finding in the 
adjudication of another immigration petition. Louisiana Philharmonic Orchestra v. INS, No. 98-
2855, 2000 WL 282785 (E.D. La.), aff'd, 248 F.3d 1139 (5th Cir. 2001), cert. denied, 122 S.Ct. 51 
(2001). 
III. CONCLUSION 
The Petitioner has not demonstrated by a preponderance of the evidence that he is an individual of 
extraordinary ability under section 203(b)(1)(A) of the Act. Accordingly, he has not established 
eligibility for the immigration benefit sought. Section 291 of the Act, 8 U.S.C. § 1361; Matter of 
Otiende, 26 I&N Dec. 127, 128 (BIA 2013). 
ORDER: The appeal is dismissed. 
Cite as Matter ofC-M-C-, ID# 12620 (AAO Nov. 22, 2016) 
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