dismissed EB-2 NIW Case: Business Management

U.S. Citizenship 
and Immigration 
Services 
In Re: 21964110 
Appeal of Nebraska Service Center Decision 
Non-Precedent Decision of the 
Administrative Appeals Office 
Date: SEP. 07, 2022 
Form 1-140, Immigrant Petition for Alien Worker (Advanced Degree, Exceptional Ability, National 
Interest Waiver) 
The Petitioner, a business management consultant, seeks second preference immigrant classification 
as either an advanced degree professional or an individual of exceptional ability in the sciences, arts 
or business, as well as a national interest waiver of the job offer requirement attached to this EB-2 
classification. See Immigration and Nationality Act (the Act) section 203(b)(2), 8 U.S.C. 
§ 1153(b)(2). After a petitioner has established eligibility for EB-2 classification, U.S. Citizenship 
and Immigration Services (USCIS) may, as matter of discretion, grant a national interest waiver if the 
petitioner demonstrates : (1) that the foreign national's proposed endeavor has both substantial merit 
and national importance; (2) that the foreign national is well positioned to advance the proposed 
endeavor; and (3) that, on balance, it would be beneficial to the United States to waive the requirements 
of a job offer and thus of a labor certification. Matter of Dhanasar, 26 l&N Dec. 884 (AAO 2016). 
The Director of the Nebraska Service Center determined that the Petitioner qualifies for the underlying 
classification and that he "possibly" submitted sufficient evidence to establish that he is well 
positioned to advance his proposed endeavor. Nevertheless, the Director denied the petition, 
concluding that the evidence did not establish the national importance of the proposed endeavor or 
that a waiver of the requirement of a job offer would be in the national interest. Accordingly, the 
Director determined that the Petitioner had not established eligibility for a national interest waiver. 
The matter is now before us on appeal. The Petitioner reasserts his eligibility, arguing that the Director 
did not review each piece of evidence properly and erred in the decision. In these proceedings, it is 
the Petitioner's burden to establish eligibility for the requested benefit. Section 291 of the Act, 
8 U.S.C. § 1361. Upon de nova review, we will dismiss the appeal. 
I. LEGAL FRAMEWORK 
To establish eligibility for a national interest waiver, a petitioner must first demonstrate qualification 
for the underlying EB-2 visa classification, as either an advanced degree professional or an individual 
of exceptional ability in the sciences, arts, or business. Because this classification requires that the 
individual's services be sought by a U.S. employer, a separate showing is required to establish that a 
waiver of the job offer requirement is in the national interest. 
Section 203(b) of the Act sets out this sequential framework: 
(2) Aliens who are members of the professions holding advanced degrees or aliens of 
exceptional ability. -
(A) In general. - Visas shall be made available ... to qualified immigrants who are 
members of the professions holding advanced degrees or their equivalent or 
who because of their exceptional ability in the sciences, arts, or business, will 
substantially benefit prospectively the national economy, cultural or 
educational interests, or welfare of the United States, and whose services in the 
sciences, arts, professions, or business are sought by an employer in the United 
States. 
(B) Waiver of job offer -
(i) National interest waiver .... [T]he Attorney General may, when the Attorney 
General deems it to be in the national interest, waive the requirements of 
subparagraph (A) that an alien's services in the sciences, arts, professions, or 
business be sought by an employer in the United States. 
Section 10l{a)(32) of the Act, 8 USC § 1101(a)(32), provides that "[t]he term 'profession' shall 
include but not be limited to architects, engineers, lawyers, physicians, surgeons, and teachers in 
elementary or secondary schools, colleges, academics, or seminaries." 
The regulation at 8 C.F.R. § 204.5(k)(2) contains the following relevant definitions: 
Advanced degree means any United States academic or professional degree or a foreign 
equivalent degree above that of baccalaureate. A United States baccalaureate degree 
or a foreign equivalent degree followed by at least five years of progressive experience 
in the specialty shall be considered the equivalent of a master's degree. If a doctoral 
degree is customarily required by the specialty, the alien must have a United States 
doctorate or a foreign equivalent degree. 
Exceptional ability in the sciences, arts, or business means a degree of expertise 
significantly above that ordinarily encountered in the sciences, arts, or business. 
Profession means one of the occupations listed in section 101(a)(32) of the Act, as well 
as any occupation for which a United States baccalaureate degree or its foreign 
equivalent is the minimum requirement for entry in the occupation. 
In addition, the regulation at 8 C.F.R. § 204.5(k)(3)(ii) sets forth the specific evidentiary requirements 
for demonstrating eligibility as an individual of exceptional ability. A petitioner must submit 
documentation that satisfies at least three of the six categories of evidence listed at 8 C.F.R. 
§ 204.5(k)(3)(i i). 
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Furthermore, while neither the statute nor the pertinent regulations define the term "national interest," 
we set forth a framework for adjudicating national interest waiver petitions in the precedent decision 
Matter of Dhanasar, 26 l&N Dec. 884 (AAO 2016). In announcing this new framework, we vacated 
our prior precedent decision, Matter of New York State Department of Transportation, 22 l&N Dec. 
215 (Act. Assoc. Comm'r 1998). Dhanasar states that after a petitioner has established eligibility for 
EB-2 classification, U.S. Citizenship and Immigration Services (USCIS) may grant a national interest 
waiver as matter of discretion. See also Poursina v. USCIS, 936 F.3d 868, 2019 WL 4051593 (9th 
Cir. 2019) (finding USCIS' decision to grant or deny a national interest waiver to be discretionary in 
nature). As a matter of discretion, the national interest waiver may be granted if the petitioner 
demonstrates: (1) that the foreign national's proposed endeavor has both substantial merit and national 
importance; (2) that the foreign national is well positioned to advance the proposed endeavor; and 
(3) that, on balance, it would be beneficial to the United States to waive the requirements of a job offer 
and thus of a labor certification. See Dhanasar, 26 l&N Dec. at 888-91, for elaboration on these three 
prongs. 
II. ANALYSIS 
The Director determined that the Petitioner qualifies as a member of the professions with an advanced 
degree. The remaining issue to consider is whether the Petitioner has established eligibility under the 
Dhanasar framework. 
A. The Proposed Endeavor 
On his Form 1-140, the Petitioner stated that his proposed occupation is as a business management 
consultant and described his duties as "[cc ]onduct organizational studies and evaluations, design 
systems and procedures, conduct work simplification and measurement studies, and prepare operations 
and procedures manuals to assis[t] management in operating more efficiently and effectively." His 
supporting evidence accompanying the petition included numerous explanations of his proposed 
endeavor. He stated in his professional plan and statement that his proposed endeavor involves 
continuing his career as a business management consultant "specialized in organizing, analyzing and 
planning various types of business operations." He will implement process improvements that can 
help companies achieve corporate goals and revenue growth; monitor and improve organizational 
processes; recommend solutions; perform research and analysis to map out workflows; change 
company activities to reduce cost and increase efficiency; automate processes; and create innovative 
management tools. In addition, he will serve companies small and large by leading improvement 
projects and developing strategies for them. The Petitioner claimed that his proposed endeavor 
services would be an asset to companies that intend to develop existing business or to start new 
business in Brazil. 
He offered numerous examples of his past accomplishments and successes for individual businesses 
in order to illustrate what he is capable of replicating through the proposed endeavor. Specifically, 
the Petitioner stated that the proposed endeavor will impact his field of work by (1) supervising 
companies' operations; (2) promoting research on business and market trends in accordance with the 
organizations' objectives and strategies; (3) developing growth concepts for companies; (4) applying 
continuous improvement (Cl) management techniques; (5) implementing matrix management 
strategies; (6) developing and implementing balanced business strategy (BBS); and (7) disseminating 
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knowledge to others through professional trainings and events. His professional plan and statement 
included additional plans under each of these areas of impact. Furthermore, the Petitioner claimed 
that through his proposed endeavor, he will serve U.S. companies by promoting research to identify 
weaknesses and opportunities, increase the number of customers, create more jobs, and ultimately 
make the business grow sustainably. 
Regarding proposed events and trainings, the Petitioner stated that he will serve as a lecturer and a 
speaker at conferences in order to reach as many professionals as possible, thereby helping the country 
to enhance its workforce knowledge in business and finance. By offering trainings within corporations 
or other institutions, such as universities and associations, he hopes to provide others with information 
regarding his techniques so as to generate broad and deep impacts within the field and the U.S. 
economy. Overall, the Petitioner believes that through his proposed endeavor, he can benefit many 
companies in a variety of industry sectors, the U.S. people, and the country as a whole. 
B. National Importance 
In support of the national importance of the proposed endeavor, the Petitioner provided several 
examples of his business consulting presentations and the plans he delivered for specific companies 
in the past. This evidence illustrates that the Petitioner is capable and qualified, which appears to 
pertain more to the second prong of the Dhanasar framework, which "shifts the focus from the 
proposed endeavor to the foreign national." Id. at 890. The issue here is whether the specific endeavor 
that the Petitioner proposes to undertake has substantial merit and national importance under 
Dhanasar's first prong. While the plans and presentations may have been important for the companies 
that utilized the Petitioner's services, this evidence is insufficient to establish how the Petitioner's 
proposed endeavor will have an impact rising to the level of national importance. 
In addition, the Petitioner provided printouts of available job opportunities and email exchanges with 
prospective employers interested in his services. This evidence suggests that the business management 
consulting field is important, that companies need business management consulting services, and that 
the Petitioner possesses the qualifications required to assist these companies. As mentioned 
previously, the Petitioner's qualifications are relevant to the second Dhanasar prong. Additionally, 
in determining national importance, the relevant question is not the importance of the industry or 
profession in which the individual will work; instead, we focus on the "the specific endeavor that the 
foreign national proposes to undertake." Id. at 889. Accordingly, while the plans, presentations, and 
job opportunities provide helpful background information, they do not establish the national 
impmiance of the Petitioner's proposed endeavor. 
The Petitioner submitted an advisory opinion letter from ______ a professor of 
marketing at I University, in which he evaluated the Petitioner's eligibility under the 
Dhanasar framework. Regarding claims concerning the substantial merit and national importance of 
the Petitioner's proposed endeavor, I I highlighted the prospective impact of the 
Petitioner's proposed endeavor in the business field. Among the impacts to the field,I I 
wrote that the proposed endeavor will expand communication channels in national and international 
markets, improve companies and revenues in the United States, offer continuous improvement (Cl) 
methodologies and business concepts to aspiring entrepreneurs and business professionals, and help 
small and medium-sized enterprises to achieve better production and profit levels. In addition, the 
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endeavor will provide business management insights to Latin American companies planning to 
conduct business in the United States, as well as U.S. companies looking to expand their business into 
the Latin American market. 
claimed that the proposed endeavor would employ U.S. workers and have substantial 
positive economic effects. In particular, he opined that as a result of the proposed endeavor, the 
Petitioner would generate revenues within the United States, create employment opportunities, and 
organize business processes for various sectors within the U.S. business field. To support these claims, 
I I stated that, as a speaker or trainer, the Petitioner would teach other professionals in the 
field, which would generate business revenue and increase workforce knowledge. I I 
further opined that the proposed endeavor would enhance societal welfare and cultural enrichment by 
increasing job opportunities. He stated that the Petitioner will implement his methodologies to 
alleviate challenges in the business sector, which would result in improvement to the social and 
cultural welfare of communities. 
While we have thoroughly considered I I opinion, it is of little probative value in this 
matter ____ does not provide sufficient evidence to corroborate the conclusions he makes 
concerning the impact of the proposed endeavor. For instance.I I noted that the Petitioner 
will implement his unique methods and strategies to increase business revenue for businesses entering 
the Latin American market; however, he did not provide any details to explain what makes the 
Petitioner's methods and strategies unique. The opinion contained assertions that the proposed 
endeavor would enhance societal welfare and cultural enrichment by increasing job opportunities and 
that the Petitioner will implement his methodologies to alleviate challenges in the business sector, 
resulting in improvement to the social and cultural welfare of communities. However.I I 
does not explain how the social and cultural welfare of U.S. communities would be improved through 
the creation of jobs, nor does he offer specific examples or other evidence to corroborate that the 
proposed endeavor would increase job opportunities. In addition.I I mentioned the 
importance of trade and business activity between Brazil and the United States, and that these activities 
have been the subject of governmental interest and action. However, the importance of trade and 
business activity is insufficient to establish the national importance of the specific proposed endeavor. 
As previously noted, the relevant question is not the importance of the industry or profession in which 
the individual will work; instead, we focus on the "the specific endeavor that the foreign national 
proposes to undertake." Id. at 889. 
As a matter of discretion, we may use opinion statements submitted by the Petitioner as 
advisory. Matter of Caron Int'l, Inc., 19 I&N Dec. 791, 795 (Comm'r 1988). However, we will reject 
an opinion or give it less weight if it is not in accord with other information in the record or if it is in 
any way questionable. Id. We are ultimately responsible for making the final determination regarding 
an individual's eligibility for the benefit sought; the submission of expert opinion letters is not 
presumptive evidence of eligibility. Id. Here, I opinion restates large portions of the 
claims the Petitioner made concerning the national importance of the proposed endeavor, but he does 
not add sufficient analysis or corroborating details to support the restated claims. 
We reviewed the letters of recommendation initially submitted; however, none of the authors discuss 
the proposed endeavor or why it is nationally important. In taking the past results the Petitioner 
achieved for other companies and extrapolating them to illustrate the results that the Petitioner may 
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produce through his proposed endeavor, we still cannot conclude that the impact would reach a level 
of national importance. Simply stating that certain statistical results occurred for a company because 
of the Petitioner's services does not establish a causal link supported by evidence. From the 
information provided, the positive effects produced within the companies could be the result of a 
variety of factors, which may include, but are not limited to, the Petitioner's services. Although, 
various authors cite statistical results to show the value and impact of the Petitioner's services, the 
claimed impact appears to be localized to the particular project or company that hired the Petitioner. 
For instance.I I Director of Operations at a large pharmaceutical conglomerate, stated 
that as a result of the management advances the Petitioner initiated, the company opened 68 new 
branches that represented R$ 200 million Brazilian reais, offered 1,700 new job positions, opened a 
new distribution center to respond to increased demand, as well as reduced costs by R$ 22 million 
reais. However, the only evidentiary link between the Petitioner's services and these results is the 
author's attestation. As stated, it cannot be determined if other factors influenced the results. In 
addition, these results, while notable, do not in themselves sufficiently suggest a national impact, as 
opposed to an impact for that particular company. 
In response to the Director's request for evidence (RFE), the Petitioner provided additional letters of 
reference, many of which contained examples of how the Petitioner's services for particular companies 
or projects created a positive impact for that company. While helping a company and its leaders 
increase profits, enabling a company to grow and hire more workers in a particular location, or 
enabling a company to expand its business into new locations are indeed important for the parties 
involved, neither the authors of the letters, nor the record in general, sufficiently supports a finding 
that the Petitioner's proposed endeavor has national importance. 
We examined the articles and reports that highlight the success of a particular pro·ect or of a com 
for which the Petitioner worked. Examples include, but are not limited to, the 
the _______ the expansion of I I and the digital 
transformation plans. However, the articles mention neither the Petitioner by name nor his specific 
services such that we can conclude that the Petitioner's past work is indicative of the Petitioner's future 
work in the proposed endeavor. Similarly, we acknowledge the articles regarding the importance of 
digital transformation in government sectors, but the Petitioner does not suggest that his proposed 
endeavor services will add anything new to the transformations already in place, nor does the evidence 
suggest that the scope of the proposed endeavor stands to impact the government. Finally, we 
acknowledge that the industry reports highlight the importance of certain business consulting services, 
note their relevance in good management, and explain how certain practices lead to success. However, 
as previously explained, it is insufficient to establish the importance of the industry or profession, but 
rather, the Petitioner must demonstrate the national importance of his specific proposed endeavor. 
Additionally, the record does not contain sufficient evidence to suggest that his proposed endeavor 
would offer the field or the nation any innovative or unique techniques. He mentioned utilizing the 
Agile framework, Lean Six Sigma, matrix management, Cl methodology, BBS, Management by 
Improvement (POCA), and Management to Sustain Results (SDCA), but he does not suggest that he 
created or developed these practices, nor does he suggest that he would be among the first to introduce 
them to the business consulting field. Evidence in the record suggests that for his current employer, 
I !Company, the Petitioner created a tool called which stands tori I 
I However, the record does not suggest that this framework is the subject 
6 
of a patent belonging to the Petitioner or that this framework is new or unfamiliar to the business 
management field. 1 Furthermore, it is unclear froml director, !whether 
the Petitioner actually created I I or whether he customized an existing framework to address 
I I specific business needs. Returning tol opinion, we again note that 
although! I referenced the Petitioner's unique methods and strategies, the record does not 
explain what these are, nor does the Petitioner offer a sufficiently direct evidentiary tie between his 
methods and strategies and the claimed results. 
While a technique or practice may be new to a particular company, the record does not suggest that 
such techniques or practices are new to the field of business consulting. Additionally, asserting that a 
company achieved a particular result after hiring the Petitioner for his services does not sufficiently 
link the Petitioner's services to the claimed results. In other words, although positive results may be 
correlated with the Petitioner's services, this is insufficient to establish that the Petitioner's services 
caused the results. Even if this had been established, the record still lacks sufficient evidence of how 
his proposed endeavor would introduce innovative, unique, or previously unknown techniques to the 
business management consulting field or that his proposed endeavor would have an impact rising to 
the level of national importance. 
As the Director stated in the decision, the proposed endeavor stands to primarily impact the individuals 
and businesses that hire the Petitioner for his services. Simply working to improve discrete businesses 
is not necessarily sufficient to establish that the proposed endeavor has national importance. The 
proposed endeavor may very well improve productivity and profit for U.S. businesses; however, the 
record lacks sufficient evidence to establish a strong connection between the proposed endeavor 
activities and job creation, broad enhancement of social welfare and cultural enrichment, or increased 
revenues on a level commensurate with national importance. Not all business activity has the potential 
to impact the economy on a nationally important scale. While the Petitioner's proposed endeavor may 
impact the individuals and businesses that engage him for his business management consulting 
services, the evidence does not suggest that the Petitioner's services will be available on a level that 
creates national or global implications in the business field. 
To illustrate further, even if the Petitioner offered his services to the public at large by drawing high 
attendance to his lectures, teaching, and speaking engagements, the Petitioner has not offered 
sufficient evidence to suggest that this would impact the business consulting field or the nation. In 
Dhanasar, we determined that the petitioner's teaching activities did not rise to the level of having 
national importance because they would not impact his field more broadly. See Dhanasar, 26 l&N 
Dec. at 893. As previously explained, the Petitioner has not demonstrated that his techniques and 
practices are unique, innovative, or new to the business field. Accordingly, the evidence does not 
support a finding that even if the Petitioner reached the public at large, that his services would impact 
the business field or the nation as a whole. 
As explained in the Director's decision, the Petitioner's statements reflect his intention to provide 
valuable services for potential employers or clients, but the evidence and information offered 
insufficiently demonstrated that the prospective impact of his proposed endeavor would rise to the 
1 The Petitioner's framework appears similar to and perhaps the same as an open-source decision making framework 
called "DACI," which stands for "driver, approver, contributor, informed." 
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level of national importance. The Director stated that the Petitioner had not shown that his endeavor 
will "sufficiently extend beyond the employer and clientele to impact the field or the nation's fiscal 
condition more broadly." The decision reflects that the Director considered the Petitioner's past 
success in business management consulting but nevertheless determined that even if the Petitioner 
replicated those results for U.S. companies through his proposed endeavor, "his help and these results 
would be contingent upon those companies hiring him to manage their projects and paying him for his 
services, indicating advancement more for the parties involved than for overall national impact." 
On appeal, the Petitioner argues that he provided evidence similar to what Dr. Dhanasar provided in 
support of the national importance of his proposed endeavor and that because we found the evidence 
had established Dr. Dhanasar's eligibility for a national interest waiver, we should likewise view the 
Petitioner's evidence as sufficient to establish his eligibility. Although the Petitioner argues for a one­
to-one comparison of his evidence to Dr. Dhanasar's evidence, the matter before us does not pertain 
to or contain evidence of Dr. Dhanasar's proposed endeavor to make such a comparison. Moreover, 
the Petitioner's proposed endeavor involves business management consulting, which is a vastly 
different proposed endeavor than Dr. Dhanasar's endeavor, which involved research into hypersonic 
propulsion. 
The Petitioner also argues on appeal for consideration of the January 2022 USCIS Policy Manual 
guidance regarding entrepreneurial and Science, Technology, Engineering, and Math {STEM) national 
interest waiver petitioners. We have reviewed and applied the guidance at 6 USCIS Policy Manual 
F.5(D), https://www.uscis.gov/policymanual to this decision. However, we nevertheless conclude that 
the Petitioner has not established the national importance of his proposed endeavor. The USCIS Policy 
Manual acknowledges that claims lacking corroborating evidence are not sufficient to meet a 
petitioner's burden of proof. As explained, the Petitioner has not provided sufficient evidence to 
support his claims concerning the impact of the proposed endeavor and how it would rise to the level 
of national importance. While the Petitioner states on appeal that he submitted a large volume of 
evidence to support his claims, 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)). It is always the Petitioner's responsibility to ensure the record 
demonstrates how he qualifies for a national interest waiver. Section 291 of the Act, 8 U.S.C. § 1361. 
The Petitioner also argues that the impact of his work at illustrates the impact of the 
Petitioner's proposed endeavor. For instance, the Petitioner notes that ___ __,offers 38,000 jobs 
worldwide, operates 78 factories, and engages 5,500 ingredient and package suppliers. However, the 
size and international scope of the company is insufficient to illustrate that his work withinl I 
is nationally important. Although the Petitioner provided letters that speak highly of the Petitioner's 
services and articles that illustrate the importance of Cl and digital transformation, the Petitioner's 
conclusion that his proposed endeavor has national importance is not corroborated by the record. 
Rather, such a conclusion requires uncorroborated assumptions to establish a connection between his 
work and an impact that rises to the level of national importance. To illustrate by example, the 
evidence does not suggest that the U.S. Gross Domestic Product (GDP) changed from when the 
Petitioner was not yet a part of thel I team to when he became part of the team and that any 
improvements to the GDP were attributable tol I and the Petitioner's services specifically. 
Whilel I may have hired the Petitioner to work on their digital transformation team, the 
Petitioner has not established that his services directly impact the position ofl lor other U.S. 
8 
companies in the international market. Even if the Petitioner had offered such evidence, it would not 
necessarily establish how individual companies' positions would be nationally important or how the 
Petitioner would offer his services on a scale reaching beyond just the companies that hire him. 
To illustrate with another example, the Petitioner suggests on appeal that increasing the size and 
profitability ofl lwill increase the number of consumers who buy I products, 
thereby introducing others to U.S. tendencies and tastes, which will attract attention to the United 
States and its culture. While we acknowledge this argument, it once again requires that we reach 
conclusions that are not corroborated by evidence. The Petitioner has not offered evidence to suggest 
that his proposed endeavor would result in the expansion of U.S. tendencies or interest in U.S. culture. 
Even if he provided such evidence, the Petitioner still has not shown how increased interest in the U.S. 
would result in a broad enhancement of society or cultural enrichment. 
On appeal, the Petitioner notes that companies that invest in Cl have achieved positive results. While 
this may be true, the companies, individuals, or entities that choose to hire the Petitioner or other 
business management consultants to initiate and carry out the Cl processes are the beneficiaries of the 
claimed positive results. The evidence the Petitioner provides does not lead to the conclusion that 
substantial positive impacts to the economy would be attributable to the Petitioner's work. 
Furthermore, as previously explained, the field of business consulting, to include services such as Cl 
and digital transformation are important; however, eligibility for a national interest waiver requires 
more than just a showing of the importance of a particular field or a profession within a field. Rather, 
the Petitioner must establish the national importance of his specific proposed endeavor. 
We conclude that the evidence provided does not sufficiently establish that either individually or 
collectively, the Petitioner's proposed endeavor services would have a significant potential to employ 
U.S. workers, generate broad impact outside the individual companies involved, or offer substantial 
positive economic effects. Even if the Petitioner's services directly resulted in enabling a company to 
expand, hire more workers, generate more profit, as well as run more efficiently and effectively, the 
Petitioner has not explained how these benefits reach past the individual parties involved. Without 
sufficient information or evidence regarding any projected U.S. economic impact or job creation 
attributable to his future work, the record does not show that benefits to the U.S. regional or national 
economy resulting from the Petitioner's business would reach the level of "substantial positive 
economic effects" contemplated by Dhanasar. See Dhanasar, 26 l&N Dec. at 890. Even if we 
aggregate the benefits the Petitioner's proposed endeavor will create across his career and lifetime, it 
is not apparent from the evidence provided that the Petitioner would impact either the business 
management consulting field or the nation as a whole. 
As the foregoing discussion demonstrates, we conclude that the Petitioner has not established the 
national importance of his proposed endeavor. Therefore, the Petitioner has not demonstrated 
eligibility for a national interest waiver. As such, further analysis of his eligibility under the second 
and third prongs outlined in Dhanasar would serve no meaningful purpose. 
Ill. CONCLUSION 
Because the identified reasons for dismissal are dispositive of the Petitioner's appeal, we decline to 
reach and hereby reserve remaining arguments concerning eligibility under the third Dhanasar prong. 
9 
See INS v. Bagamasbad, 429 U.S. 24, 25 (1976) ("courts and agencies are not required to make 
findings on issues the decision of which is unnecessary to the results they reach"); see also Matter of 
L-A-C-, 26 l&N Dec. 516, 526 n.7 (BIA 2015) (declining to reach alternative issues on appeal where 
an applicant is otherwise ineligible). 
As the Petitioner has not met the requisite first prong of the Dhanasar analytical framework, we 
conclude that he has not established he is eligible for or otherwise merits a national interest waiver. 
The appeal will be dismissed for the above stated reason. 
ORDER: The appeal is dismissed. 
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