dismissed EB-1C Case: Retail

identifying data deleted to 
prevent clearly unwarranted 
invasion of personal privacy 
Pl rnuc copy 
FILE: 
IN RE: Petitioner: 
Beneficiary: 
U.S. Department of Homeland Security 
U.S. Citizenship and Immigration Services 
Administrative Appeals Office (AAO) 
20 Massachusetts Ave., N.W., MS 2090 
Washington, DC 20529-2090 
u.s. Citizenship 
and Immigration 
Services 
Office: TEXAS SERVICE CENTER Date: 
MAR 1 7 2011 
PETITION: Immigrant Petition for Alien Worker as a Multinational Executive or Manager Pursuant to 
Section 203(b)(I)(C) of the Immigration and Nationality Act, 8 U.S.C. § 1153(b)(I)(C) 
ON BEHALF OF PETITIONER: 
INSTRUCTIONS: 
Enclosed please find the decision of the Administrative Appeals Office in your case. All of the 
documents related to this matter have been returned to the office that originally decided your case. 
Please be advised that any further inquiry that you might have concerning your case must be made to 
that office. 
If you believe the law was inappropriately applied by us in reaching our decision, or you have 
additional information that you wish to have considered, you may file a motion to reconsider or a 
motion to reopen. The specific requirements for filing such a request can be found at 8 C.F .R. 
§ 103.5. All motions must be submitted to the office that originally decided your case by filing a 
Form 1-2908, Notice of Appeal or Motion, with a fee of $630. Please be aware that 8 C.F.R. § 
103.5(a)(1 )(i) requires that any motion must be filed within 30 days of the decision that the motion 
seeks to reconsider or reopen. 
Th~Yo/: 
4:~ri!1.-­
;i1e:;'Rhew 
Chief, Administrative Appeals Office 
www.uscis.gov 
Page 2 
DISCUSSION: The Director, Texas Service Center, initially approved the employment-based 
immigrant visa petition, and ultimately revoked the approval of the petition following the issuance of 
a notice of intent to revoke. The matter is now before the Administrative Appeals Office (AAO) on 
appeal. The appeal will be dismissed. 
The petitioner filed the instant immigrant petition on September 12, 2001 to classify the beneficiary 
as a multinational manager or executive pursuant to section 203(b)(l)(C) of the Immigration and 
Nationality Act (the Act), 8 U.S.C. § 1 1 53(b)(l)(C). The petitioner claims to be a limited 
partnership organized in the State of Texas that owns, manages and operates retail stores. The 
petitioner seeks to employ the beneficiary as its president. 
• The director approved the employment-based immigrant petition on March 5, 2002. On May 24, 
2004, U.S. Citizenship and Immigration Services (USCIS) requested further evidence in connection 
with the beneficiary'S Form 1-485, Application to Register Permanent Resident Status of Adjust 
Status. On February 6, 2009, the director issued a Notice ofintent to Revoke (NOIR) approval of the 
petition on the grounds that, based on inconsistencies between the documentation the petitioner 
provided in response to the 1-485 request for further evidence and that submitted with the 1-140, the 
petitioner had failed to establish that a qualifYing relationship exists between the U.S. petitioner and 
the beneficiary'S foreign employer. 
After reviewing the petitioner's response to the NOIR, the director revoked the approval of the 
petition on March 24, 2009. The director concluded that the petitioner had failed to establish that 
there exists a qualifYing relationship between the U.S. petitioner and the beneficiary's foreign 
employer. The director found the petitioner has not shown that the foreign entity and the U.S. 
petitioner have similar ownership or controlling interests such that they can be considered affiliates 
as claimed. The director also noted that the evidence of record does not show that the individual 
who signed the Form 1-140 had the authority to submit petitions on the company's behalf. 
On appeal, counsel for the petitioner asserts that the director's decision is in error. Counsel contends 
that the petition may not be revoked because the beneficiary is already inside the United States. 
Counsel claims that the person who submitted the petition on behalf of the petitioner has indirect 
ownership interest in the petitioner and, therefore, has authority to file the petition. Counsel further 
contends that the foreign company and the U.S. company are affiliated since the beneficiary holds 
partnership interest in both entities. 
I. Revocation of an Approved Immigrant Petition 
At the outset, the AAO will address counsel's contention that procedurally, the USCIS may not 
revoke the petition because the beneficiary is already physically present in the United States. Here, 
counsel relies on Firstland Int'!, Inc. v. Ashcroft, 377 F.3d 127 (2d Cir. 2004), where the United 
States Court of Appeals for the Second Circuit interpreted section 205 of the Act, 8 U.S.C. § 1155 
(2003), to render the revocation of an approved immigrant petition ineffective where the beneficiary 
of the petition did not receive notice of the revocation before beginning his journey to the United 
States. Firstland, 377 F.3d at 130. Counsel asserts that, pursuant to First/and, USCIS may not 
Page 3 
revoke the approval because the beneficiary was already in the United States when the director 
issued the revocation. 
It is noted that neither the beneficiary nor the petitioner in this instance resides or is located within 
the jurisdiction of the Second Circuit. Furtbennore, Firstland is no longer a binding precedent. On 
December 17, 2004, the President signed the Intelligence Refonn and Terrorism Prevention Act of 
2004 (S. 2845). See Pub. L. No. 108-458,118 Stat. 3638 (2004). Specifically relating to this matter, 
section 5304( c) of Public Law 108-458 amends section 205 of the Act by striking "Attorney 
General" and inserting "Secretary of Homeland Security" and by striking the final two sentences. 
Section 205 of the Act now reads: 
The Secretary of Homeland Security may, at any time, for what he deems to be good 
and sufficient cause, revoke the approval of any petition approved by him under 
section 1154 of this title. Such revocation shall be effective as of the date of approval 
of any such petition. 
8 U.S.c. § 1155 (2005) 
Further, section 5304( d) of Public Law 108-458 provides that the amendment made by section 
5304( c) took effect on the date of enactment and that the amended version of section 205 applies to 
revocations under section 205 of the Act made before, on, or after such date. Accordingly, the 
amended statute specifically applies to the present matter, and the AAO does not find persuasive 
counsel's claim that the director is barred from revoking the petition under these circumstances. 
Regarding the finding of "good and sufficient cause" for the revocation of an immigrant petition 
under section 205 of the Act, the Board of Immigration Appeals (BIA) has stated: 
In Matter of Estime, ... this Board stated that a notice of intention to revoke a visa 
petition is properly issued for "good and sufficient cause" where the evidence of 
record at the time the notice is issued, if unexplained and unrebutted, would warrant a 
denial of the visa petition based upon the petitioner's failure to meet his burden of 
proof. The decision to revoke will be sustained where the evidence of record at the 
time the decision is rendered, including any evidence or explanation submitted by the 
petitioner in rebuttal to the notice of intention to revoke, would warrant such denial. 
Matter of Ho, 19 I&N Dec. 582, 590 (BIA 1988) (citing Matter of Eslime, 19 I&N Dec. 450 (BIA 
1987)). 
By itself, the director's realization that a petition should not have been approved based on the 
evidence provided is good and sufficient cause for the issuance of a notice of intent to revoke an 
immigrant petition. Matter of Ho, 19 I&N Dec. at 590. Accordingly, the AAO finds that, contrary to 
counsel's claim, the director is not procedurally barred from revoking the petition under these 
circumstances. 
Page 4 
The AAO stresses that the petitioner must establish that the petitioner and beneficiary were eligible 
for the benefit sought at the time the instant petition was filed on September 12, 2001. A petition 
cannot be approved at a future date after the petitioner or beneficiary becomes eligible under a new 
set offacts. Matter of Katigbak, 14 I&N Dec. 45, 49 (Comm. 1971). 
The petition approval in this matter was ultimately revoked due to the director's subsequent 
determination, upon reviewing additional evidence the petitioner provided, that the petition was 
erroneously approved in March 2002, rather than based on a conclusion that the beneficiary and 
petitioner became ineligible for the benefit sought after the approval ofthe petition. Accordingly, the 
AAO will confine its analysis of the evidence to documentation that is contemporaneous with the 
beneficiary'S priority date of September 12,2001. 
The evidence in the record of proceeding dates from 2000 through 2009. Federal regulations 
affirmatively require an alien to establish eligibility for an immigrant visa at the time an application 
for adjustment of status is filed or when the visa is issued by a United States consulate. 8 C.F.R. § 
245.l(a), 22 C.F.R. § 42.41. The petitioner bears the ultimate burden of establishing eligibility for 
the benefit sought, and that burden is not discharged until the immigrant visa is issued. Tongatapu 
Woodcraft of Hawaii, Ltd. v. Feldman, 736 F.2d 1305 (9th Cir. 1984). In the present matter, no 
immigrant visa was issued as a result of the petitioner's approved Form 1-140. Therefore, the 
petitioner's burden to maintain eligibility for the benefit sought continued well beyond 2001 and did 
not terminate simply because the 1-140 was approved. 
II. The Law 
Section 203(b) of the Act states, in pertinent part: 
(1) Priority Workers. -- Visas shall first be made available ... to qualified immigrants 
who are aliens described in any of the following subparagraphs (A) through (C): 
• • * 
(C) Certain Multinational Executives and Managers. - An alien is 
described in this subparagraph if the alien, in the 3 years preceding 
the time of the alien's application for classification and admission 
into the United States under this subparagraph, has been employed 
for at least I year by a firm or corporation or other legal entity or an 
affiliate or subsidiary thereof and who seeks to enter the United 
States in order to continue to render services to the same employer or 
to a subsidiary or affiliate thereof in a capacity that is managerial or 
executive. 
The language of the statute is specific in limiting this provision to only those executives or managers 
who have previously worked for the firm, corporation or other legal entity, or an affiliate or 
subsidiary of that entity, and are coming to the United States to work for the same entity, or its 
affiliate or subsidiary. 
Page 5 
A United States employer may file a petition on Form 1-140, Immigrant Petition for Alien Worker, 
for classification of an alien under section 203(b )(1 )(C) of the Act as a multinational executive or 
manager. No labor certification is required for this classification. The prospective employer in the 
United States must furnish a job offer in the form of a statement, which indicates that the alien is to 
be employed in the United States in a managerial or executive capacity. Such a statement must 
clearly describe the duties to be performed by the alien. 
III. Qualifying Relationship 
The primary ground for revocation of the petition is the director's determination that the petitioner 
has failed to establish that it has a qualifYing relationship with the beneficiary's foreign employer. 
On the Form 1-140 submitted on September 12, 2001, the petitioner stated its name as 
In an attachment to the Form 1-140, the petitioner states that ' •••• 
the [p]etitioner herein," is a Texas limited partnership established in February 2000 
that is "majority owned and controlled" by the beneficiary. The petitioner also stated that ••• 
___ the beneficiary's foreign employer in Pakistan, "is also majority owned and controlled" by 
the beneficiary. The petitioner claimed that the U.S. and foreign companies are therefore affiliates 
based on common ownership. 
Documentation relating to the foreign entity submitted with the Form 1-140 included: a Chamber of 
Commerce membership certificate; various business certificates and license; bank statements; 
documents entitled "Assessment Orders" issued by the "Income Tax/Wealth Tax Department 
Lahore" for the years 1998-1999, 1999-2000 and 2000-2001; and a number of documents entitled 
"Notice of Demand Under Section 85 of the Income Tax Ordinance, 1979" dated from December 
1997 through December 2000. The Assessment Orders state that the toreig,n c(Jm]parlY 
association of persons consisting of two and 
The respective ownership interests of the members are not stated in any of 
" 
With respect to the U.S. company, the petitioner submitted: a number of leases for its retail 
locations; its Texas Sales and Use Permit dated April 1, 2000; the company's Internal Revenue 
Service (IRS) Form 1065, U.S. Return of Partnership Income, for the year 2000; bank statements (in 
the name of "Quantum Petroleum LLC") for January through March 2001; and IRS Forms W-2, 
Wage and Tax Statements, for its employees. Schedules K to the petitioner's 2000 IRS Form 1065 
identify as general partners of the U.S. company, with 
34%,33% and 33% ownership, respectively. 
The petition was approved on March 5, 2002. Subsequently, the director issued a request for 
additional evidence on May 24, 2004, in connection with the beneficiary's Form 1-485. Among 
other things, the director requested a current letter of employment or job offer. In response to that 
request, the beneficiary submitted an undated letter on its letterhead, signed by as 
president, confirming that the beneficiary "has been working with [the company], continuously as a 
General Partner since he received his L-I A visa on June 21, 2000" and that the company "would like 
Page 6 
to employ him pennanently as a General Partner starting from the day that he receives his pennanent 
residence status ... " 
In the NOIR issued on February 6, 2009, the director stated that conflicting infonnation was found in 
the record and noted the following: 
1. An individual named signed the F onn 1-140 and the original F onn G-
28, Notice of Entry of Appearance as Attorney or Representative, on behalf of the 
petitioner, and also signed, as president of the petitioner, the letter confinning the 
beneficiary's employment as "General Partner" of the petitioner. However, according 
to the Fonn 1-140 and the Fonn G-325-A, Biographic Infonnation, submitted with the 
Fonn 1-485, the beneficiary is president of the company, not Mr. ••• 
2. The petitioner's limited partnership agreement dated February 17,2000 shows that the 
general partner is (owned by the beneficiary) with 0.1 % 
interest, and the limited partners are the beneficiary with 50.9% interest and 
with 49% interest. There is no evidence that 
is a limited partner or president. 
3. With respect to the foreign entity, the director noted that the record contains no 
documentation showing the actual ownership of the company. 
The director stated that, based on these deficiencies in the record, the petitioner and the foreign 
entity do not appear to be affiliates and, consequently, the beneficiary does not qualifY for the 
requested classification. 
The petitioner responded to the NOIR in a letter dated March 4,2009. The petitioner confinned that 
its ownership structure at the time the original petition was filed was as stated in the NOIR. The 
petitioner further explained that the general partner of the petitioner, "has the 
exclusive right and authority to manage the business affairs" of the petitioner, including the authority 
to appoint as the president of the company at the time the petition was filed. 
However, the petitioner claimed, that appointment "in no way changes the fact the ultimate 
management decisions with regard to the business of [the petitioner) have always rested with 
_which is wholly owned and managed by [the beneficiary) as president." The petitioner 
further asserted that the 0.1% ownership interest in the petitioner, combined with the 50.9% 
ownership interest held by the beneficiary, gives the beneficiary a majority ownership interest in the 
petitioner. 
With respect to the foreign entity, the petitioner claimed that at the time the petition was filed, the 
foreign entity was a general organized under the laws of Pakistan owned 50% by the 
beneficiary and 50% who died in March 2002. The petitioner asserted that 
irrespective of interest in the foreign entity, the beneficiary'S 50% ownership is 
sufficient to render the foreign entity and the petitioner affiliates. The petitioner submitted a copy of 
a partnership deed, dated January 1, 1995, between the beneficiary and 
as partners "in equal shares." 
Page 7 
Lastly, the petitioner explained that the letter confirming the beneficiary's employment that was 
submitted in connection with his 1-485 "should have stated that [he] owns the general partner entity 
not that he himself is the general partner." 
The director issued a notice of revocation of the petition on March 24, 2009, based on the grounds 
expressed in the NOIR. 
On appeal, as already addressed above, counsel for the petitioner contends that the revocation of the 
petition is in error because USCIS "adopted the statutory language of INA §205 without taking into 
account applicable case law and the fact that the beneficiary ... is already inside the United States." 
Counsel further argues that "[a]pplicable case law requires a much broader definition of 'affiliate' 
than that adopted by the Service in this case" and that "[u]nder applicable case law, the definition of 
'affiliate' would encompass the relationship that existed between the Petitioner and the foreign 
business entity." Counsel cites a number of cases, but did not elaborate on their applicability to the 
present facts. Counsel further claims that in referring to the petitioner as an LLC, limited liability 
company, rather than an LP, limited partnership, the Service is confused about the nature of the 
beneficiary's ownership interest in the petitioner and, therefore, the affiliation between the petitioner 
and the foreign entity. Finally, counsel asserts that has the authority to submit the 
petition on behalf of the petitioner since he has a 50% interest in Northwest Petroleum, which in tum 
has a 49% interest in the petitioner. 
With respect to counsel's assertion that the director's decision demonstrates confusion and lack of 
understanding of the U.S. company's corporate formation, the AAO notes that the petitioner itself 
introduced this confusion, as the evidence of record is inconsistent in its references to the company's 
name. It is noted that the petitioner described itself in the attachment to the Form 1-140 as a limited 
and its IRS Form 1065 for the year 2000 identifies the petitioner as 
However, on the Form 1-140 itself, the petitioner stated its name as 
" On copies of bank statements submitted with the Form 1-140, the petitioner's name 
is also stated as ' rather than "LP." The petitioner has provided no 
explanation for these inconsistencies in references to its own name in the record. It is incumbent 
upon the petitioner to resolve any inconsistencies in the record by independent objective evidence. 
Any attempt to explain or reconcile such inconsistencies will not suffice unless the petitioner 
submits competent objective evidence pointing to where the truth lies. Matter of Ho, 19 I&N Dec. at 
591-92. Further, contrary to counsel's claim, the AAO does not find that the confusion regarding the 
petitioner's name has any bearing on the director's substantive analysis ofthe criteria for eligibility in 
this instance. 
The AAO now turns to the issue of whether the petitioner has established that it has a qualifying 
relationship with the foreign entity. To establish a "qualifying relationship" under the Act and the 
regulations, the petitioner must show that the beneficiary'S foreign employer and the proposed U.S. 
employer are the same employer (i.e. a U.S. entity with a foreign office) or related as a "parent and 
subsidiary" or as "affiliates." See generally § 203(b)(l)(C) ofthe Act, 8 U.S.C. § 1153(b)(I)(C); see 
also 8 C.F.R. § 204.50)(2) (providing definitions of the terms "affiliate" and "subsidiary"). 
Page 8 
The regulation at 8 C.F .R. § 204.5(j)(2) states in pertinent part: 
Affiliate means: 
(A) One of two subsidiaries both of which are owned and controlled by the same 
parent or individual; 
(B) One of two legal entities owned and controlled by the same group of 
individuals, each individual owning and controlling approximately the same 
share or proportion of each entity. 
Multinational means that the qualifYing entity, or its affiliate, or subsidiary, conducts 
business in two or more countries, one of which is the United States. 
Subsidiary means a firm, corporation, or other legal entity of which a parent owns, 
directly or indirectly, more than half of the entity and controls the entity; or owns, 
directly or indirectly, half ofthe entity and controls the entity; or owns, directly or 
indirectly, 50 percent of a 50-50 joint venture and has equal control and veto power 
over the entity; or owns, directly or indirectly, less than half of the entity, but in fact 
controls the entity. 
The regulation and case law confirm that ownership and control are the factors that must be 
examined in determining whether a qualifying relationship exists between the United States and 
foreign entities for purposes of this visa classification. Matter of Church Scientology International, 
19 I&N Dec. 593 (BIA 1988); see also Matter of Siemens Medical Systems. Inc., 19 I&N Dec. 362 
(BIA 1986); Matter of Hughes, 18 I&N Dec. 289 (Comm. 1982). In the context of this visa petition, 
ownership refers to the direct or indirect legal right of possession of the assets of an entity with full 
power and authority to control; control means the direct or indirect legal right and authority to direct 
the establishment, management, and operations of an entity. Matter of Church Scientology 
International, 19 I&N Dec. at 595. 
Here, as the petitioner claims that the U.S. and foreign entity are "affiliates," the petitioner must 
establish that both entities "are owned and controlled by the same parent or individual" or "owned and 
controlled by the same group of individuals, each individual owning and controlling approximately the 
same share or proportion of each entity." The AAO finds that the record is insufficient to support the 
conclusion that the there is a qualifying relationship between the two entities. 
With respect to the ownership of the U.S. company, the director noted that the petitioner's limited 
partnership agreement dated February 17,2000 indicates that the company's general partner is ••• 
~~!~~=:~w~l~·th~O~.~1 O~Yo~in~t:er:est, and the limited partners are the beneficiary with 50.9% 
interest and with 49% interest. In to the NOIR, the petitioner 
confirmed the above information and further claimed that is wholly owned by 
the beneficiary; therefore, the beneficiary owned 51 % in the company, a majority ownership interest, 
at the time of filing. However, according to Schedules K to the petitioner's IRS Form 1065 for the 
year 2000, the company is 34% owned by the beneficiary, 33% owned by j and 33% 
Page 9 
owned by Thus, the ownership structure described in the partnership agreement is 
inconsistent with, and appears to be superseded by, the ownership information disclosed in the 
petitioner's 2000 tax return, which presumably reflects the U.S. company's ownership as of 
December 31, 2000. Further, there is no evidence that in between the filing of the 2000 tax return 
and the filing of this petition in September 2001, the ownership structure of the U.S. company 
reverted back to that described in the original partnership agreement. The petitioner has failed to 
address these inconsistencies regarding its ownership structure at the time the petition was filed. It is 
incumbent upon the petitioner to resolve any inconsistencies in the record by independent objective 
evidence. Again, any attempt to explain or reconcile such inconsistencies will not suffice unless the 
petitioner submits competent objective evidence pointing to where the truth lies. Matter of Ho, 19 
I&N Dec. at 591-92. In light of these unresolved inconsistencies, and in the absence of further 
evidence, the AAO cannot determine the ownership structure of the U.S. company at the time the 
petition was filed. 
With respect to the foreign entity, the only evidence of its . structure in the record is the 
partnership deed dated January I, 1995, in which the beneficiary and ' are 
described as partners. The deed stated that the initial capital was to be provided by the partners "in 
equal shares," and also stipulated that "further capital ... shall be contributed by the partners in equal 
share." There is no evidence that this partnership "in equal share" remained in place as of the date 
the petition was filed. Even assuming that the deed remained in effect, it would only demonstrate 
that the foreign entity is owned in equal share by the beneficiary and another individual who has no 
ownership interest in the U.S. company. There is no evidence to indicate that both the foreign entity 
and the petitioner are "owned and controlled by the same parent or individual" or "the same group of 
individuals, each individual owning and controlling approximately the same share or proportion of each 
entity" at the time the petition was filed. 
Accordingly, the record is insufficient to demonstrate that the petitioner and the foreign entity are 
affiliates, as the petitioner claimed. Nor does the record establish that a parent-subsidiary 
relationship exists between the two entities. As such, the petitioner has failed to meet the 
requirement of establishing that a qualifying relationship existed at the time the petition was filed 
between the petitioner and the beneficiary's foreign employer. 
Finally, counsel claims on appeal that USCIS erroneously concluded that 
authority to submit petitions on behalf of the petitioner. Counsel claims 
to act on behalf of the petition stems from his 50% partnership interest in 
which in turn has a 49% interest in the However, the record contains no documentation 
of ownership interest in nor his claimed authority to act on 
behalf of the petitioner. Without documentary evidence to support the claim, the assertions of 
counsel will not satisry the petitioner's burden of proof. The unsupported assertions of counsel do 
not constitute evidence. Matter of Obaigbena, 19 I&N Dec. 533, 534 (BIA 1988); Matter of 
Laureano, 19 I&N Dec. I 1983); Matter of Ramirez-Sanchez, 17 I&N Dec. 503, 506 (BIA 
1980). Further, signed the Form G-28 submitted with the Form 1-140 as "limited 
partner," whereas K to the petitioner 2000 tax return listed him as a general partner. This 
inconsistency has not been addressed by the petitioner or by counsel. 
-Page 10 
More importantly, the petitioner's and counsel's claims regarding role in the company 
reveal further material inconsistencies in the record regarding the claimed position of the beneficiary 
in the . As noted earlier, the record contains a letter on the petitioner's letterhead, signed by 
as president, submitted in response to the director's request for evidence in May 2004 
in connection with the beneficiary's 1-485 petition. The letter confirms that the beneficiary "has been 
working with [the company], continuously as a General Partner since he received an L-IA visa on 
June 21, 2000" and that the company "would like to employ him permanently as a General Partner 
starting from the day that he receives his permanent residence status ... " The fact that 
signed the 2004 letter as the president of the company and his statement that the beneficiary has 
always been employed by the petitioner as "general partner" are inconsistent with all of the 
petitioner's representations in the Form 1-140 and its supporting documentation that the beneficiary 
was to be employed as president of the company. In addition, it is noted that the beneficiary's Form 
G-325, Biographic Information, submitted with the beneficiary's Form 1-485, also states that the 
beneficiary was president of the petitioner from March 2000 to "present time." The petitioner'S 
assertion in response to the NOIR that __ statement in his 2004 letter regarding the 
beneficiary's role in the company is an error based on advice of counsel is not persuasive. Again, it 
is incumbent upon the petitioner to resolve any inconsistencies in the record by independent 
objective evidence. Any attempt to explain or reconcile such inconsistencies will not suffice unless 
the petitioner submits competent objective evidence pointing to where the truth lies. Matter of Ho, 
19 I&N Dec. at 591-92. Doubt cast on any aspect of the petitioner's proof may, of course, lead to a 
reevaluation of the reliability and sufficiency of the remaining evidence offered in support of the 
visa petition. Id. 
Based on the foregoing discussion, the AAO finds that the director's notice of revocation was 
properly issued for "good and sufficient cause," and that the revocation of the petition approval was 
warranted. See Matter of Ho, 19 I&N Dec. at 590. Accordingly, the appeal will be dismissed. 
In visa petition proceedings, the burden of proving eligibility for the benefit sought remains entirely 
with the petitioner. Section 291 of the Act, 8 U.S.C. § 1361. Here, that burden has not been met. 
ORDER: The appeal is dismissed.