dismissed EB-2 NIW Case: International Studies

U.S. Citizenship 
and Immigration 
Services 
In Re: 19519098 
Appeal of Texas Service Center Decision 
Non-Precedent Decision of the 
Administrative Appeals Office 
Date: NOV. 03, 2021 
Form 1-140, Immigrant Petition for Alien Worker (Advanced Degree, Exceptional Ability, National 
Interest Waiver) 
The Petitioner, an assistant professor of international studies, seeks second preference immigrant 
classification as 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 Texas Service Center Director determined that the Petitioner qualifies for classification as an 
advanced degree professional and that the proposed endeavor has substantial merit and national 
importance. However, the Director concluded that the evidence did not establish that the Petitioner is 
well positioned to advance the endeavor, or that a waiver of the required job offer, and thus of the 
labor certification, would be in the national interest. 
On appeal, the Petitioner offers a brief and additional evidence to argue that she qualifies for a national 
interest waiver. 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 (emphasis added), 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 101 (a)(32) of the Act provides that "[t]he term 'profession' shall include but not be limited to 
architects, engineers, lawyers, physicians, surgeons, and teachers in elementary or secondary schoo Is, 
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)(ii). 
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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 discretionaty in 
nature). As a matter of discretion, the national interest waiver may be granted if the petitioner 
demonstrates: (1 )thatthe foreignnational'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. 
11. ANALYSIS 
The Director found that the Petitioner qualifies as a member of the professions holding an advanced 
degree. The Petitioner holds a doctorate degree in international studies, which she earned from a U.S. 
university in 2015. The Director found that the evidence of record established the substantial merit and 
national importance of the proposed endeavor. However, upon de nova review and for the reasons 
discussed below, we must withdraw the Director's conclusion that the Petitioner met the national 
importance portion of the first prong. In addition, we agree with the Director that the evidence does 
not establish the Petitioner's eligibility under the second Dhanasar prong. 
A National Importance 
Although the Director determined that the Petitioner's proposed endeavor has both substantial merit 
and national importance, we withdraw the Director's finding concerning the national importance portion 
of the Petitioner's eligibility under the first Dhanasar prong. As the below discussion illustrates, we 
conclude that the evidence is insufficient to support a finding thatthe endeavor has national importance. 
On the Form 1-140, Immigrant Petition for Alien Worker, which the Petitioner filed in January 2019, 
she provided the following information: 
Part 5 - Additional Information About the Petitioner 
Section 11. Occupation: International Relations Researcher 
Part 6 - Basic Information About the Proposed Employment 
Section 1. Job Title: Assistant Professor in International Studies 
Section 2. SOC Code: 19-3094 
Section 3. Nontechnical Job Description: Prepare and deliver lectures to college students 
on topics such as International Relations, Security Studies. Conduct research in 
International Studies field, publish findings in professional journals. 
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The Petitioner's resume indicates that at the time of filing, she held an adjunct professor position at 
I I, as well as served as an international consultant for thel I I , 0 , ,I and as a contributing analyst tori l On her 
ETA 750 Part B, the Petitioner listed her employment as an international consultant and as a 
contributing analyst but stated that she held her position as an adjunct professor withc=Jonly until 
December 2018. Also on the ETA 750 Part B, she listed her prospective position as an international 
relations researcher and referred our attention to her personal statement for further details. In viewing 
the Petitioner's Form I-140, resume, and ETA 750 Part B collectively, we note discrepancies both in 
whether the Petitioner is currently employed as a professor, as well as whether her intended 
employment is as a professor or solely as a researcher. 
Her personal statement provided background concerning her past accomplishments, as well as her 
future research plans and job o[portunities. The Petitioner stated that in the coming years, she intends 
to "extend [her] research on !foreign policy to support civil society as the 
cornerstone of improved maintenance of public affairs in emerging societies and countries" and that 
herresearch "addresses fundamental issues for lasting peace and stability in the world." She expressed 
certainty that she will "make a significant contribution to enhancing the studf of nattonal security 
issues." She further clarified that she intends to extend her "prior research on s geopolitical 
challenges to the United States andl lby using new and more advanced approaches to obtain a 
proper database o~ I propaganda, segmented ly medij' topic, target audience, and reach, that 
greatly improves the works of all analysts studying information warfare." The Petitioner 
explained that she is seeking employment opportunities to continue her work and noted that she had 
an interview for an assistant professor position scheduled with the international studies department of 
the Universit~ I She also stated that she was certain of her ability to 
r1i,od,suitable employment within her field once she receives a visa. The record contains emails from 
L_Jassigning the Petitioner to teach two Spring 2019 courses, as well as requesting her course 
preferences for Summer and Fall 2019. Additionally, the Petitioner asserted that she conducts peer 
reviews of others' academic work and serves as on the editorial board of1 I. an academic 
journal. 
Based upon the information provided, the Petitioner's future plans remain unclear. As previously 
noted, her statement on the Form 1-140 indicates that her proposed employment is as an assistant 
professor in international studies, while her Form ETA 750, Part B indicates her prospective 
employment will be as an international relations researcher. The conflicting information provided 
prevents us from determining if the Petitioner currently works as an adjunct professor and if so, how 
much time she will devote to teaching as opposed to research. This is significant, as we determined 
in Dhanasar that the petitioner's teaching activities did not rise to the leve I of having national 
importance because they would not impact his field more broadly. Id. at 893. In addition, we cannot 
ascertain how much time the Petitioner intends to devote to research while also pursuing her 
consulting, analyst, peer review, and editorial board activities. 
Finally, the Petitioner appears to be engaged in an active employment search, as evidenced by her 
interview for an assistant professor position at the Universit'A I and her 
statement that she is certain to find suitable employment. The Petitioner did not provide details on 
what "suitable employment" involves and we cannot ascertain whether her proposed endeavor 
activities will encompass this future and unknown employment or whether she intends to perform 
4 
research outside of and apart from whatever "suitable employment" she finds. We question what the 
Petitioner's proposed endeavor actually involves and note that the purpose of a national interest waiver 
is not to afford a petitioner an opportunity to engage in a U.S. job search. In Dhanasar, we held that 
a petitioner must identify "the specific endeavor that the foreign national proposes to unde1iake." Id. 
at 889. Although the record contains explanations of past and current employment and research, we 
have insufficient information concerning the Petitioner's proposed future endeavor to co nc I ude that it 
has national importance. 
To evaluate whether a petitioner's proposed endeavor satisfies the national importance requirement, 
we look to evidence documenting the "potential prospective impact" of the work. With respect to the 
Petitioner's teaching, we conclude that the record does not establish by a preponderance of the 
evidence that such activities would impactthe field of international relations more broadly, as opposed 
to being limited to the specific students and university she may serve. The Petitioner has not included 
sufficient evidence of the specific future activities she will engage in, which inhibits a determination 
concerning the proposed endeavor's broader impact and therefore its national importance. 
Accordingly, we conclude that her endeavor, as currently described, does not meet the first prong of 
the Dhanasar framework. 
A review of the Petitioner's evidence does not clarify her proposed endeavor, nor persuasively establish 
its national importance. The Petitioner provided on line commentary from academic and news sources 
asserting the significance and relevance of the international relations field, particularly to U.S. interests. 
However, 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." See Id. at 889. Although the Petitioner 
asserted that her "state-of-the-art research in international relations offers novel insight into the 
position of the [United States] in the global world order, which guides the development and 
implementation of informed foreign policies that optimize outcomes for both the United States and its 
international partners," she has not provided sufficient documentation to substantiate these claims. 
The Petitioner has not explained how her research is "state-of-the-art" or even what such a claim 
means in the context of research. For instance, she has not asserted that her research methods are new 
or different from traditional research methods or the methods already used by others. Furthermore, 
the claim that she offers "novel insights" is not supp01ied by the record. In examining the 
documentation, we observe evidence that many others study, publish, and offer their research-based 
perspectives on similar topics. The record contains insufficient evidence to support a finding that the 
Petitioner's research has offered novel insights, particularly as the record contains evidence 
demonstrating that other researchers have also considered similar concepts. 
The Petitioner offered evidence of her research publications and that at the time of filing her petition in 
January 2019, her work had been cited nine times. While we acknowledge that evidence of the impact 
her past work has had provides a basis to suggest that her future work will have a similar impact, this past 
research acclaim does not in itself establish the national importance of the proposed endeavor. Here, the 
Petitioner has not identified the specificnatureof her proposed future activities so that we might determine 
the endeavor's possible impact, nor has she identified how any future research would be disseminated 
into the community such that its potential can be properly evaluated. To illustrate, if the Petitioner holds 
an adjunct professor position while also researching, this may inform how she publishes and disseminates 
her research ideas. Alternatively, if she performs research independently and holds nootheremploymeni 
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we question how she will fund her research work and publish any findings concerning it. Finally, 
obtaining undefined "suitable employment" at an unknown time could detract from the time she might 
devote to research. As the impact created by such scenarios would vary, we conclude that the Petitioner 
has not established how her past research record supports a f indingthat herfutureworkwill have asimilar 
impact or that such impact would rise to the level of national importance. 
Although we acknowledge the Petitioner's claims that her research has informed foreign policy, the 
record does not contain sufficient or persuasive evidence to support such a conclusion. We reviewed the 
letter from I I which the Petitioner submitted inresp,nseto the Director's request for 
evidence (RFE). I I the Director of Public Policy at asserted that thel I I I a combat command of the United States Department of Defense, "funded the Petitioner's 
efforts to understand! lgovemment intentions through a study of state media." While we 
acknowledge this letter and the rintout of a report co-authored by the Petitioner concerning the role of 
I the record contains insufficient evidence to corroborate I I 
claims. For instance, the record does not contain evidence, such as a money transfer, check, or contract, 
to corroborate that any U.S. defense enti aid the Petitioner to conduct this study. Moreover, the 
documentation does not suggest that the ado ted an olicies as a result of the 
Petitioner's study. The news article printout regarding the~-------~s work inc=J 
I I provides helpful background into the possible reasons for commissioning a study, but the article 
does not suggest that the Petitioner's research had any bearing on thel l's policies 
or that they specifically commissioned the Petitioner to conduct research on their behalf. In addition, 
although! I claims to be a former researcher within thd I, it is unclear 
when he left that role and joined his current role a nor can we ascertain the nature ofl l's 
authority to comment on behalf of the,___ _______ _. Based upon this evidence, the Petitioner 
has not established her research has informed foreign policy or that her proposed endeavor has national 
importance. 
While the Petitioner submitted numerous letters of recommendation from other researchers and 
academics in the field, few authors discussed the Petitioner's proposed future endeavor. Instead, the 
authors primarily focused on the Petitioner's past work. As such, these letters do not assist in our 
understanding of the proposed endeavor. In examining the authors' claims concerning the Petitioner's 
past research, we observe that the impact of her research appears limited to academia. The authors 
offer little detail to substantiate a finding that the Petitioner's research has affected the international 
relations field as a whole. Although! !asserted that the Petitioner's research 
onl I national security policy has provided insights that inform the foreign policy of the United 
States, neither this letter nor the record substantiates such a claim. Similarly, although! I I I described the Petitioner's research as "groundbreaking," her publications as "influential," and 
that she has proposed "innovative frameworks," he offered insufficient detail to explain such 
assertions. For instance, he did not explain why her research was groundbreaking or different, who or 
what specifically her publications have influenced, or what innovative frameworks she has proposed 
for understanding foreign policy inl I Likewise, ~------~commented on the 
Petitioner's "innovative approach" as an example of the Petitioner's vital role in the field but offered 
little detail to explain what the Petitioner's approach is or how it is innovative in comparison to others 
in the field. 
6 
Generalized conclusory statements that do not identify a specific impact in the field have little 
probative value. See 1756, Inc. v. US. Atty Gen., 745 F. Supp. 9, 15 (D.D.C. 1990) (holding that an 
agency need not credit conclusory assertions in immigration benefits adjudications). The submission 
of reference letters supporting the petition is not presumptive evidence of eligibility; USCIS may 
evaluate the content of those letters so as to determine whether they support the petitioner's 
eligibility. Id. See also Matter of V-K-, 24 l&N Dec. 500, n.2 (BIA 2008) (noting that expert opinion 
testimony does not purport to be evidence as to "fact"). 
Overall, the Petitioner has not clearly identified how her research activities fit in with her future 
employment plans. The record does not include consistent information or sufficient supporting 
evidence identifying how the Petitionerwill allocate her time between her various activities or whether 
her proposed endeavor of research includes employment as a professor or in some other position that 
she will find at an unknown future time. As she has not identified what specific future activities she 
will engage in and how, the Petitioner has not established that her proposed endeavor will have a 
broader impact or national importance. For the foregoing reasons, we withdraw the Director's finding 
concerning the Petitioner's eligibility under the first Dhanasar prong and conclude instead that the 
evidence is insufficient and lacks the requisite detail necessary to support a finding that the endeavor has 
national importance. 
B. Whether the Petitioner is Well Positioned to Advance the Proposed Endeavor 
As the Petitioner has not established eligibility under the first Dhanasar prong, eligibility under the 
second and third prongs is moot. A national interest waiver is only available to those who establish 
eligibility for the underlying classification and under all three prongs of the Dhanasar framework. 
Nevertheless, because the Director made additional findings concerning the Petitioner's eligibility under 
the second Dhanasar prong and the Petitioner asserts error in those fin dings, we provide additional 
analysis concerning the Petitioner's eligibility under the second Dhanasar prong. As previously 
explained, the record contains conflicting information concerning whether the Petitioner is currently 
employed as a professor and how her research activities fit in with her future employment plans. The 
unclear nature of the proposed endeavor inhibits a proper assessment of whether the Petitioner is well 
positioned to advance it. 
Analysis under the second prong shifts the focus from the proposed endeavor to the Petitioner. In our 
precedent Dhanasar decision, we found "[t]he petitioner's education, experience, and expertise in his 
field, the significance of his role in research projects, as well as the sustained interest of and funding from 
government entities such as NASA and AFRL, position him well to continue to advance his proposed 
endeavor of hypersonic technology research." Id. at 893. Although the record demonstrates that the 
Petitioner's advanced degree is relevant to international relations research and that she has some 
experience in the field, the Petitioner has not persuasively established her expertise, that she holds a 
significant role in her field, that there is sustained interest in her work, or that she has received funding 
for her past research or for her future endeavor. Accordingly, the evidence is insufficient to conclude that 
the Petitioner is well positioned to advance her endeavor. 
We acknowledge that the Petitioner authored a book and additional individual chapters published within 
larger collections of research, and that these publications had collectively garnered nine citations at the 
time of filing. In addition, we acknowledge the Petitioner's appellate arguments concerning the 
7 
limitations of Google Scholar and that Microsoft Academic affords an improved perspective on the 
Petitioner's record of success. However, as Dhanasar demonstrates, we look to a variety of factors in 
determining whether a petitioner is wel I positioned to advance the proposed endeavor and citations are 
merely one factor among many that may contribute to such a finding. While nine citations may indicate 
some level of success in her field of endeavor, such a citation record does not persuasively support the 
Petitioner's claim that her work is widely recognized. Moreover, much of the Petitioner's published 
research appears intertwined with or supported by her former research faculty supervisor,! I I I For example,! !wrote the Petitioner's first book review and many of the Petitioner's 
published chapters appear inl l's textbook materials. The Petitioner has not provided persuasive 
evidence of her expertise and experience in research that is independent from the support and established 
platform provided by her former faculty research! supervirr. Additionally, the Petitioner appears as a co­
author on a research report concerning the role of news mediairl land it is therefore 
not apparent how much of the Petitioner's own research went into th is report. Based upon th is evidence, 
it appears as though the Petitioner has received collaborative support from others in producing research 
and we question her record of success in producing research independently. 
The Petitioner submitted evidence that others have reviewed her work and provided their opinions on her 
publications, which she argued supports a finding that her work has been favorably received in the field 
of international relations. In examining the reviews, we observe that mostappearto be general summaries 
or supposition concerning possible future impact. For instance, a Ph.D. candidatesummarizedthe various 
chapters of an overall publication that contains one chapter the Petitioner wrote. The candidate's 
summary provides no commentary on how the Petitioner has influenced the field or any indication that 
the Petitioner's work has been favorably received. Although~----~• a political candidate in 
the United Kingdom, wrote that the Petitioner'sworkwill certainly challenge scholars' views! I 
offered little explanation for such an assertion, nor did she claim that the Petitioner's work had any actual 
impact on the field. Further, the record does not establish what professional credentials! I 
possesses to offer her opinion on the Petitioner's work. Similarly,! I reviewed the 
Petitioner's written work and offered his own summary of it but did not offer any comment on its quality, 
impact, or importance in the field. The Petitioner further claimed that researched I reviewed 
her work; however, the record merely contains I Is online biography and does not contain any 
review of the Petitioner's work. Based on the evidence provided, the reviews of the Petitioner's written 
work do not suggest a record of success or favorable status in the field that wou Id position her well to 
advance the proposed endeavor. 
The Petitioner also claimed that she received U.S. government funding for her research and that this 
funding su arts a finding that she is well positioned to advance her endeavor. The Petitioner provided 
a copy of a contract for her work as a consultant on a project from November 2017 to May 2018. 
A letter from the ~-~project officer indicated that the United States Agency for International 
Development (USAID) funded the project. The Petitioner's consultant role involved analyzing an 
academic writing program at a university in.~ _____ ,.......... in order to improve the university's 
writing courses and the overall curriculum in the region. The record does not contain evidence to support 
a finding that the Petitioner received USAI D funding for her proposed endeavor or that the funding she 
received extended beyond the university writing project. Furthermore, the evidence suggests the 
Petitioner received funding for her consultancy work in instructional methods and educational policy, 
rather than for international relations research. In addition, the source of funding appears notto have been 
8 
available to the Petitioner since the close of her contract in May 2018. Accordingly, the past funding she 
received for her consultancy work has no bearing on her positioning to advance her proposed endeavor. 
The Petitioner also claimed that she received $4,000 from thd I to investigate 
I I news media coverage and their posture towards~----~As previously discussed, the 
only evidence the Petitioner provided to support such an assertion is a letter from the Director of Public 
Policy atl I This evidence is secondary and not persuasive of actual payment or a request for the 
Petitioner to conduct research on behalf of the U.S. military. Moreover, the letter lacks specific dates and 
other corroborative and verifiable details. We further conclude that it does not persuasively establish the 
author's prior work as a researcher fou _________ ........, or his authority to comment on behalf of 
I I Even if we were to accept the Petitioner's contention that she received U.S. 
military funding for her research, this would still be insufficient to support a finding that such funding 
would be available for use in pursuing her proposed endeavor or that she is currentlywell positioned to 
advance her endeavor because of it. 
The Petitioner also asserted that her position on an editorial board and her peer review of others' written 
work establishes her expertise in the field and thereby positions her well to advance the proposed 
endeavor. However, the Petitioner has not persuasively supported her contention that these activities 
suggest she has expertise in her field or that these activities improve her ability to carry out the proposed 
endeavor. For instance, the Petitioneroffered little information concerning I how her setvice 
on the board positions her as a leader in the field, what her duties are as a member, or how much time she 
spends on her editorial board duties. Similarly, the Petitioner has not offered data on how many articles 
she has peer reviewed in relation to other researchers in her field, or how the reputation of the journals 
and the peers for whom she reviews indicates that the Petitioner is an expert in her field. In addition, 
whether her proposed endeavor involves international relations research or teaching international 
relations as a professor, the Petitioner's work as a member on an editorial board or as a peer reviewer 
appears to take time away from her other proposed endeavor activities. Accordingly, even if we were to 
accept the Petitioner's argument that this work demonstrates that she is an expert in her field, it would 
nevertheless fai I to demonstrate how she is wel I positioned to carry out her endeavor. 
In her RFE response, the Petitioner asserted that she received a prestigious fellowship based on her 
outstanding contributions to the field. She presented a letter from the Chief Executive Officer of the 
~-----------------___.which stated that they identified the Petitioner 
as an "outstanding scholar" and that she was selected to receive a fellowship "based on her reputation for 
producing important research relevant to understanding th~ I region." The Petitioner 
provided little information concerning what this fellowship conferred upon her or how it is considered 
prestigious. It is not apparent how many other scholars received this fellowship, how many were 
considered overall, what qualifications! I considered in making its determination, or 
whether the fellowship is known beyond the presenting organization. Accordingly, we conclude that this 
fellowship does not support a finding that the Petitioner's reputation in the field positions her well to 
advance her proposed endeavor. 
Returning once again to the Petitioner's recommendation letters, we observe that most authors discuss 
the Petitioner's past research contributions. Most authors appear to have little knowledge of the 
Petitioner's current or future employment or funding, nor have the authors provided details concerrring 
the international relations community's interest in the Petitioner's proposed future work. As the 
9 
Petitioner's current and future employment status remains unclear, we question her ability to 
predominantly pursue research in a manner commensurate with the authors descriptions of her past work. 
Accordingly, the past success the authors described is insufficient to support a finding that the Petitioner 
is well positioned to carry out her future endeavor. 
For the foregoing reasons, the evidence is insufficient to establish that the Petitioner is well positioned to 
advance the proposed endeavor. Because the documentation in the record does not establish: (1) the 
national importance of the Petitioner's proposed endeavor as required by the first prong of the Dhanasar 
precedent decision; or (2) that the Petitioner is well positioned to advance the proposed endeavor under 
the second prong, the Petitioner has not demonstrated eligibility for a national interest waiver. Further 
analysis of hereligibilityunderthe third prong outlined in Dhanasarwould serve no meaningful purpose. 
Ill. CONCLUSION 
The appeal will be dismissed for the above stated reasons, with each considered as an independent and 
alternate basis for the decision. 
ORDER: The appeal is dismissed. 
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