dismissed EB-2 NIW Case: History

U.S. Citizenship 
and Immigration 
Services 
Non-Precedent Decision of the
Administrative Appeals Office 
Date: JUNE 27, 2024 In Re: 31455435 
Appeal of Texas Service Center Decision 
Form 1-140, Immigrant Petition for Alien Workers (National Interest Waiver) 
The Petitioner, a historian, seeks employment-based second preference (EB-2) immigrant 
classification as a member of the professions holding an advanced degree or as an individual of 
exceptional ability. Immigration and Nationality Act (the Act) section 203(b)(2), 
8 U.S.C. § 1153(b)(2). The Petitioner also seeks a national interest waiver of the job offer requirement 
that is attached to this EB-2 immigrant classification. See section 203(b)(2)(B)(i) of the Act, 8 U.S.C. 
§ 1153(b)(2)(B)(i). 
The Director of the Texas Service Center denied the petition, concluding that the Petitioner did not 
establish that she is eligible for or otherwise merits anational interest waiver as a matter of discretion. 
The matter is now before us on appeal. 8 C.F.R. § 103.3. 
The Petitioner bears the burden of proof to demonstrate eligibility by apreponderance of the evidence. 
Matter of Chawathe, 25 l&N Dec. 369, 375-76 (AAO 2010). We review the questions in this matter 
de nova. Matter of C hrista 's, Inc., 26 l&N Dec. 537, 537 n.2 (AAO 2015). Upon de nova review, 
we will dismiss the appeal. 
I. LAW 
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. Section 203(b)(2)(B)(i) of the Act. 
Once a petitioner demonstrates eligibility for the underlying classification, the petitioner must then 
establish eligibility for a discretionary waiver of the job offer requirement " in the national interest." 
Section 203(b)(2)(B)(i) of the Act. U.S. Citizenship and Immigration Services (USCIS) may grant 
this discretionary waiver of the required job offer, and thus of a labor certification, when it is in the 
national interest to do so. While neither the statute nor the pertinent regulations define the term 
"national interest," Matter of Dhanasar, 26 I &N Dec. 884 (AAO 2016), provides the framework for 
adjudicating national interest waiver petitions. Dhanasar states USC IS may, as amatter of d iscretion,1 
grant a national interest waiver if the petitioner demonstrates that: 
• The proposed endeavor has both substantial merit and national importance; 
• The individual is well-positioned to advance their proposed endeavor; and 
• On balance, waiving the job offer requirement would benefit the United States. 
Id. at 889. 
11. ANALYSIS 
The Director found that the Petitioner qualifies for the EB-2 classification as a member of the 
professions holding an advanced degree. 2 We agree that the record supports that determination. 
The issue on appeal is whether the Petitioner established that a waiver of the requirement of a job 
offer, and thus a labor certification, would be in the national interest. The Director determined that 
while the Petitioner demonstrated the proposed endeavor has substantial merit, she did not establish 
that the proposed endeavor is of national importance, as required by the first prong of the Dhanasar 
analytical framework. The Director further determined that although the Petitioner established that 
she is well positioned to advance the proposed endeavor under Dhanasar's second prong, shed id not 
establish 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 under Dhanasar's third prong. Upon de nova review, we 
agree with the Director's determination that the Petitioner did not demonstrate that a waiver of the 
labor certification would be in the national interest. 3 
The first prong of the Dhanasar analytical framework, substantial merit and national importance, 
focuses on the specific endeavor that a petitioner proposes to undertake . The endeavor's merit may 
be demonstrated in a range of areas, such as business, entrepreneurial ism, science, technology, culture, 
health, or education. In determining national importance, the relevant question is not the importance 
of the field, 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. 
The Petitioner proposes to establish a business in Massachusetts for which she would be its chief 
executive officer. She indicates that her business would primarily provide expert witness services and 
country condition reports to non-profit organizations, law firms, and U.S. immigration individual 
applicants. The expert witness services would focus on safeguarding immigrants and upholding 
human rights through asylum by assisting low-income, vulnerable individuals who seek immigration 
benefits in the United States, in particular Brazilian and Latin America victims of domestic violence, 
human trafficking, and other crimes. By providing reports and opinion letters about the state of human 
1 See Flores v. Garland, 72 F.4th 85, 88 (5th Cir. 2023) Gaining the Ninth, Eleventh, and D.C. Circuit Courts (and Third 
Circuit Court in an unpublished decision) in concluding tba t USCIS' decision to grant or deny a national interest waiver 
to be discretionary in nature). 
2 To demonstrate she is an advanced degree professional , the Petitioner submitted her diplomas, her academic transcripts, 
and an academic evaluation . The record demonstrates that she holds the foreign equivalent of a U.S. master 's degree in 
history and the foreign equivalent of a doctor of philosophy in history . See 8 C.F.R. § 204.5(k)(3). 
3 While we may not discuss every document submitted, we have reviewed and considered each one. 
2 
rights and other conditions in Brazil, the Petitioner maintains her business will ensure others 
understand the culture and social conditions of Brazil so that "legal decisions are based on accurate 
information and that justice is served." She claims that her business would impact immigration and 
legal assistance on a national scale by broadly enhancing U.S. national welfare, culture, and the 
economy. We agree with the Director that the Petitioner's proposed endeavor to provide expert 
witness services has substantial merit. 
In add ition to the expert witness services for immigrants, her business will "offer advisory services 
related to market analysis to investors and businesses in both the [United States] and Brazil. The 
services will be aimed at improving the overall operational and other activities of businesses, which 
will likely further contribute to the development of the local economy." The business plan explains 
that"[ a ]ccording to anumber of sources, market research is vital for businesses of all sizes, regardless 
of the industry they are operating in, and provides real data which can be used to improve and 
strengthen various parts of the company." The Petitioner included a letter of intent from a financial 
services company interested in hiring the Petitioner's business to provide financial analysis, 
investment management, and tax compliance services. 
The Director did not address this additional proposed endeavor, instead limited the decision to the 
Petitioner's p1imary endeavor of providing expert witness services for immigrants. On appeal, the 
Petitioner argues that her business' market analysis advisory services would "attract foreign 
investment ... to the [United States], thereby contributing to the development of the local economy" 
and that her business plan details her business' contributions to attracting such foreign investments. 
Although the Petitioner and her business plan generally mention her intent to offer market analysis 
advisory services to U.S. and foreign businesses and the benefits of foreign investment to the U.S. 
economy, the Petitioner has not provided evidence further describing these services. Instead, the 
evidence mainly focuses on her proposed endeavor to provide expert witness services for immigrants 
with a few general statements regarding her proposed market analysis advisory services. Without 
further evidence describing her proposed market analysis advisory services, we are unable to 
determine whether such endeavor has substantial merit or is of national importance. Therefore, our 
decision only addresses the Petitioner's proposed endeavor to provide expert witness services for 
immigrants. 
Even though the Director determined that the Petitioner's proposed endeavor to provide expert witness 
services for immigrants has substantial merit, the Director found that the Petitioner did not establish 
that her proposed endeavor is of national importance. Specifically, the Director concluded that the 
Petitioner did not demonstrate her proposed endeavor would extend beyond her business and clients 
to have a broader impact rising to the level of national importance or that it would offer substantial 
positive economic effects as contemplated by Dhanasar. On appeal, the Petitioner claims that the 
evidence and arguments presented meet the burden of proof by a preponderance of the evidence. She 
maintains that the Director ignored evidence that establishes the national significance of her proposed 
business activities, in particular her business plan, opinion letters, national initiatives aligned with her 
endeavor, letters of interest, and published articles. 
The standard of proof in this proceeding is a preponderance of the evidence, meaning that a petitioner 
must show that what is claimed is "more likely than not" or "probably" true. Matter of Chawathe, 
25 I &N Dec. at 375-76. To determine whether a petitioner has met the burden under the 
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preponderance standard, we consider not only the quantity, but also the quality (including relevance, 
probative value, and credibility) of the evidence. Id.; Matter of E-M-, 20 l&N Dec. 77, 79-80 (Comm'r 
1989). Upon de nova review, the Petitioner has not demonstrated that the evidence submitted 
establishes her eligibility by a preponderance of the evidence, as discussed below. 
The Petitioner argues that her business plan explains how her business will provide "essential services" 
to an increasing Brazilian population in the United States. With such growing Brazilian population, 
her business would contribute to helping immigrant workers, entrepreneurship, and foreign direct 
investments which would impact the local and national economies. She maintains that her business 
"aligns with broader national goals" that would "benefit immigrants and enhance the U.S. legal 
system, leading to tangible economic growth and societal benefits ... . " Her business would reduce 
domestic violence, assist victims regain stability, and support immigrant entrepreneurs, thereby 
improving the U.S. economy with increased employment and tax payments. She argues that she 
submitted sufficient evidence showing her business will provide significant economic benefits to 
economically depressed areas in Massachusetts, pointing out that the evidence shows the 
unemployment rates of cities in various Massachusetts cities, as well as an economic impact 
assessment and community benefit analysis showing how her business "would contribute to local 
economic development, job creation, and overall community upliftment" in the economically 
depressed communities. 
The Petitioner's statements and a business plan indicate her proposed endeavor has national 
importance based on potential economic, societal welfare, and cultural benefits to economically 
depressed communities and the United States. The Petitioner will establish her business in 
economically depressed cities in thel IMassachusetts area with plans to expand to Florida, 
California, and Texas by its fifth year of business. By establishing her business in these areas, she 
claims that her business would "directly address critical national issues like economic revitalization in 
underprivileged regions and the integration ofimmigrants into the U.S. workforce." The business plan 
claims her endeavor's national-level impact through its support of asylum for victims of domestic 
violence, human trafficking, and crime; its support of U.S. government initiatives that ease asylum 
restrictions; its inspiration for women entrepreneurship; transferring the Petitioner's expertise and 
knowledge to the U.S. market; its support of the U.S. economy as a small business; and U.S. economic 
benefits through job creation and tax payments. The business plan also describes the Petitioner's 
academic credentials, professional experience, and achievements; recommendations from colleagues 
and professors; the importance of entrepreneurs; an analysis of asylum in the United States and in 
Massachusetts; the role and importance of expert witnesses for the legal system and asylum seekers; 
and the business' projected marketing, staffing, and financial calculations. 
The business plan stresses the growth of the Brazilian immigrant population and the importance of 
expert witness services to vulnerable immigrants seeking asylum and other immigration benefits. 
While we recognize the importance of supporting human rights and legal immigration and related 
careers; merely establishing an expert witness services business for low-income immigrants is 
insufficient to establish the national importance of the proposed endeavor. Instead, we focus on the 
"the specific endeavor that the foreign national proposes to undertake." Matter of Dhanasar, 26 I&N 
Dec. at 889. We acknowledge that safeguarding immigrants and upholding human rights demonstrates 
substantial merit of a proposed endeavor; however, it does not render a proposed endeavor nationally 
important under Dhanasar 's framework, as it does not in itself establish the proposed endeavor's 
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impact in the field. The issue here is whether the Petitioner has established how her proposed endeavor 
would affect national legal immigration, human rights, or the U.S. economy more broadly consistent 
with national importance. The Petitioner has not sufficiently documented the potential prospective 
impact, including the asserted economic, societal welfare, and cultural benefits to the United States 
and the areas it intends to serve. 
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. Id. at 893. We noted that 
"[a]n undertaking may have national importance for example, because it has national or even global 
implications within a particular field, such as those resulting from certain improved manufacturing 
processes or medical advances." Id. at 889. Here, the evidence does not suggest that the Petitioner's 
work establishing an expert witness services business for low-income immigrants would impact the 
immigration and human rights fields more broadly, rather than benefitting her business and clients. 
In addition to evaluating the endeavor's broad impact to the field, we noted in Dhanasar that "[a]n 
endeavor that has significant potential to employ U.S. workers or has other substantial positive 
economic effects, particularly in an economically depressed area, for instance, may well be understood 
to have national importance." Id. at 890. While any economic activity has the potential to positively 
impact the economy, the Petitioner has not offered a sufficiently direct connection between her 
proposed endeavor's activities and its impact potentially having a demonstratable substantial 
economic benefit to the economically depressed communities in Massachusetts or the nation. 
For instance, the business plan projects that in five years the business will hire 14 direct employees, 
create 29 indirect jobs, pay wages of over one million dollars, and generate almost $200,000 in income 
taxes. However, the business plan does not sufficiently detail the basis for its financial and staffing 
projections, or adequately explain how these projections will be realized. The Petitioner has not 
provided corroborating evidence demonstrating that her business' future staffing levels and business 
activities stand to provide substantial economic benefits to the United States and the communities it 
will serve. The Petitioner must support her assertions with relevant, probative, and credible evidence. 
See Matter of Chawathe, 25 l&N Dec. at 376. Also, it is unclear whether the staffing and financial 
projections also relate to the Petitioner's other endeavor, market analysis advisory services work. 
Even if everything the Petitioner claims were to happen, she has not established that creating 14 direct 
jobs and 29 indirect jobs, paying wages of over one million dollars, and generating $200,000 in income 
taxes over a five-year period rises to the level of national importance. 
While the Petitioner expresses her desire to contribute tothe United States, its economically depressed 
communities, and vulnerable immigrants, she has not established with specific, probative evidence 
that her endeavor has the potential to have broader implications in the immigration and human rights 
fields, significant potential to employ U.S. workers, or other substantial positive economic effects in 
economically depressed areas of Massachusetts or the United States. Statements and claims alone are 
not sufficient to demonstrate her endeavor has the potential to provide economic, societal welfare, and 
cultural benefits to the economically depressed communities and the United States. Also, without 
sufficient documentary evidence that her proposed job duties as chief executive officers of her expert 
witness services business would impact the immigration and human rights field more broadly, rather 
than benefiting her business and her clients, the Petitioner has not demonstrated by a preponderance 
of the evidence that her proposed endeavor is of national importance. 
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The Petitioner further argues that the opinion letters from experts in the field confirm the national 
importance of her proposed endeavor. She claims the letters articulate "the substantial positive 
economic effects of [the Petitioner's] role as an entrepreneur and as an expert witness." Specifically, 
she claims that the opinion from an associate professor of strategic management and entrepreneurship 
at I I shows "the significant role" the Petition er would have as an entrepreneur and an 
expert witness in contributing to U.S. economic growth by "aligning with [U.S.] leadership in 
entrepreneurship, innovation, and business creation." The Petitioner points to the opinion's data on 
the market size and the increase in demand for expert witness consultants and the importance of 
entrepreneurs to creating new opportunities and fostering ad iverse economy. 
The opinion states that the Petitioner 's "proposed endeavor as an entrepreneur and an expert witness 
is a pressing priority for [the United States], particularly, in terms of immigration and human rights 
and hence an endeavorof substantial merit and national importance." The opinion stresses the growing 
demand for and importance of expert witness services for individuals seeking immigration relief, and 
that the Petitioner 's expertise and knowledge would contribute to the industry. By extending access 
to expert witness services to individuals of limited financial resources, the opinion states that the 
Petitioner's endeavor would enhance societal welfare by protecting a vulnerable population, 
immigrants who have been subject to domestic violence, human trafficking, persecution, and other 
crimes. The opinion also explains the importance of immigrants and entrepreneurs to innovation and 
the growth of the U.S. economy; the importance of providing resources and support to victims of 
domestic violence and abuse; the increase in the number of individuals seeking asylum and awaiting 
their hearings; the importance of expert witnesses on the impact of asylum cases; the economic 
benefits of expert witness services on immigration and human rights; and the growth of the expert 
witness consulting industry. 
To evaluate whether the Petitioner's proposed endeavor satisfies the national importance requirement, 
we look to evidence documenting the "potential prospective impact" of her work . Id. at 889. The 
opinion 's general statements that the Petitioner's business would have a potential prospective impact 
to the U.S. economy, innovation, business creation, and social welfare are not sufficient to demonstrate 
the national importance of the Petitioner's proposed endeavor. The opinion focuses on the need for 
entrepreneurs and expert witnesses for asylum cases, and how the Petitioner's experience makes her 
capable to provide expert witness services to vulnerable immigrants seeking asylum in the United 
States, instead of the Petitioner's specific endeavor having a prospective impact in the fields of 
immigration and human rights. Stating that the Petitioner 's work would support an important field 
with a need for qualified professionals is not sufficient, in and of itself, to meet the "national 
importance" requirement under the Dhanasar framework. The submission of letters from experts 
supporting a petition is not presumptive evidence of eligibility. Matter of Caron Int'I, 19 l&N Dec. 
791, 795 (Comm'r. 1988); see also Matter of D-R, 25 l&N Dec. 445,460 n.13 (BIA2011) (discussing 
the varying weight that may be given expert testimony based on relevance, reliability, and the overall 
probative value). 
The Petitioner submitted another opinion from the associate dean for research and partnerships and 
professor of law atl I The opinion describes the Petitioner's role in her 
business, including her expert witness services, training employees, hiring sociologists and analysists 
from other countries, developing and implementing business strategies, overseeing her business, 
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recruitment and hiring of employees, and business development. The opinion provides an analysis of 
the impact of violent crimes on individuals and their communities; the prevalence of domestic violence 
in Brazil; resources to assist victims of abuse who are seeking asylum or other immigration benefits 
in the United States; and the positive economic, social, and cultural impacts of immigrants and 
immigrant entrepreneurs on the United States and Massachusetts. Similar to the opinion discussed 
above, this opinion also indicates that the Petitioner's endeavor would have substantial positive 
economic effects and describes the economic benefits of immigration and immigrant entrepreneurs. 
The opinion claims the Petitioner's endeavor will impact matters that are the subject of national 
initiatives and names immigration benefits aimed to protect immigrants, refugees, and asylum seekers. 
The opinion also claims that the Petitioner's endeavor will enhance individual and societal welfare 
and describes how immigration promotes cultural diversity, improves human rights, addresses a 
shortage of workers, improves standards of living, enhances social services, and strengthens family 
ties. 
We recognize the importance of providing services to immigrants, particularly victims of human rights 
violations, domestic violence, human trafficking, and other crimes, as well as the significant 
contributions from immigrants who work in the United States and who have become successful 
entrepreneurs. However, merely working in the expert witness field or starting an expert witness and 
market analysis advisory services business for vulnerable immigrants is insufficient to establish the 
national importance of the proposed endeavor. Instead of focusing on the importance of a field or the 
need for workers in a specific industry, we focus on the "the specific endeavor that the foreign national 
proposes to undertake." Matter of Dhanasar, 26 I&N Dec. at 889. In Dhanasar, we noted that "we 
look for broader implications" of the proposed endeavor and that "[a]n undertaking may have national 
importance for example, because it has national or even global implications within a particular field." 
Id. 
The Petitioner further claims her endeavor aligns with national initiatives by directly supporting U.S. 
immigration legislation, such as legislation relating to the Violence Against Women Act, U 
nonimmigrants, and cancellation of removal. By contributing to implementation of these laws, the 
Petitioner argues her work will bolster the legislations' intended impact on vulnerable immigrant 
communities and the legal system. While the importance of the U.S. government initiatives and 
legislation is not in dispute, their overall significance does not establish the national importance of the 
Petitioner's proposed endeavor. The support of immigrants and victims of domestic violence, human 
trafficking, and other crimes are important to the U.S. economy and societal welfare, but it does not 
follow that an individual providing expert opinion services for individual immigrants has national 
importance. Working in or establishing a business in an important field is insufficient on its own to 
establish the national importance of the proposed endeavor. The Petitioner does not quantify the 
proposed endeavor's expected impact in the identified areas ofconcern, or provide objective, probative 
evidence to support her contentions. Although the Petitioner has shown that supporting immigrants 
and victims of domestic violence, human trafficking, and other crimes are nationally important issues, 
she has not demonstrated the potential prospective impact of her specific endeavor to such nationally 
important matters. 
To further show the national importance of her proposed endeavor, the Petitioner argues that a 
recommend ation letter from her professor shows her "significant academic contributions and potential 
impact on U.S. academic and professional communities in Brazilian history and human rights." She 
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claims the letter attests to her expertise, as well as the importance of her endeavor in national education 
and social priorities. The professor explains her participation in reviewing the Petitioner's thesis and 
her work contributions to Brazilian historical works, including the Petitioner's authored work relating 
to the history of the Department of Political and Social Order and political police agencies in Brazil. 
The professor attests to the Petitioner's ability to conduct research, analyze data, and communicate 
her findings. This recommendation letter and other similar letters from the Petitioner's research and 
professor colleagues explain the Petitioner's academic work, her research skills, and knowledge of 
Brazilian history, while also expressing that her knowledge would be valuable to the success of her 
expert witness services business. 
The Petitioner has not offered sufficient information and evidence based on these recommendation 
letters to demonstrate her claims of her proposed endeavor providing broader impact in her field rising 
to the level of national importance. While the Petitioner's professors and colleagues generally attest 
to the Petitioner's research and communication skills and her dedication to historical analysis, the 
content of these letters relates to the second prong of the Dhanasar framework, instead of speaking to 
the national importance of the Petitioner's proposed endeavor. The second prong of the Dhanasar 
framework "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 national 
importance under Dhanasar 's first prong and she has not submitted sufficient documentary evidence 
to establish that her proposed job duties as chief executive officer of her expert witness services 
business would impact the immigration and human rights fields more broadly, rather than benefiting 
her business and her clients. See id. at 889. 
On appeal, the Petitioner takes issue with the Director's analysis of a letter of intent to hire the 
Petitioner. She maintains that the letter of intent from a non-profit organization shows that a quasi­
governmental entity has demonstrated an interest in working with the Petitioner, thereby substantiating 
her credibility and aligning her endeavor with national interests. We acknowledge that evidence of 
interest from government or quasi-government entities may help show the national importance of a 
proposed endeavor under Dhanasar 's first prong. See generally 6 USCIS Policy Manual 5(0)(3), 
https://www.uscis.gov/policy-manual. However, the Petitioner does not explain or provide evidence 
showing that the letter of intent is from an interested government or quasi-governmental entity, such 
as a federally funded research and development center. See generally id. Instead, the Petitioner 
indicates the letter is from a non-profit organization. The record also includes additional letters of 
intent, including a letter from an attorney who is interested in her expert witness services. However, 
because the letters are not from government or quasi-government entities, they do not necessarily show 
that her endeavor has the potential to impact matters of national interest or rises to the level of national 
importance. 
Lastly, to demonstrate her proposed endeavor is of national importance, the Petitioner argues that she 
submitted articles describing the "pivotal role" expert witnesses have in legal proceedings and in 
aiding attorneys understand complex issues. She maintains her expert witness services would provide 
"critical knowledge about country conditions, contributing to immigrants' claims for asylum orrelief." 
The record includes reports and articles relating to rural counties facing decreases in population; 
immigrants benefiting rural communities; economic benefits of immigration; cultural organizations 
promoting diversity of cultural expressions; benefits of immigrant entrepreneurs; Brazilian immigrants 
in the United States; and the role, history, and benefits of expert witnesses. As discussed earlier, while 
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we recognize the importance of expert witnesses in the legal system and related careers, and the 
significant contributions from immigrants, the Petitioner's proposal to work in the immigration and 
human rights fields and starting an expert witness services business are insufficient to establish the 
national importance of her endeavor. The industry reports and articles submitted describe the benefits 
of immigration and do not discuss any projected benefits specifically attributable to the Petitioner's 
proposed endeavor that rise to the level of national importance as contemplated by Dhanasar. 
Based on the above, the Petitioner has not demonstrated that her proposed endeavor has the potential 
to extend beyond her business and her future clients to impact the immigration and human rights fields 
or the economy or societal welfare more broadly at a level commensurate with national importance. 
Moreover, she has not demonstrated that the work she proposes to undertake offers innovations that 
contribute to advancements in her industry or otherwise has broader implications for her field, the 
economy, or societal welfare. As aresult, the Petitioner has not established that her proposed endeavor 
satisfies the national importance element of Dhanasar's first prong. 
111. CONCLUSION 
Because the Petitioner has not established the national importance of her proposed endeavor as 
required by the first prong of the Dhanasar precedent decision, she has not demonstrated eligibility 
for anational interest waiver as a matter of discretion. The identified basis for denial is dispositive of 
the Petitioner's appeal, therefore we decline to reach and hereby reserve the Petitioner's eligibility and 
appellate arguments regarding the second and third prongs under the Dhanasar framework. See INS 
v. Bagamasbad, 429 U.S. 24, 25 (1976) (noting that "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). 
The appeal will bed ismissed for the above stated reasons. 
ORDER: The appeal is dismissed. 
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