dismissed EB-2 NIW Case: Soccer Coaching

U.S. Citizenship 
and Immigration 
Services 
Non-Precedent Decision of the
Administrative Appeals Office 
Date: APR. 18, 2024 In Re: 30172482 
Appeal of Texas Service Center Decision 
Form 1-140, Immigrant Petition for Alien Workers (National Interest Waiver) 
The Petitioner, a soccer administration manager and coach, seeks employment-based second 
preference (EB-2) immigrant classification as an individual of exceptional ability, as well as anational 
interest waiver of the job offer requirement attached to this classification. See Immigration and 
Nationality Act (the Act) section 203(b)(2), 8 U.S.C. § 1153(b)(2). 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. 
The Director of the Texas Service Center denied the petition. The Director concluded that the record 
did not demonstrate the Petitioner merits a discretionary waiver of the job offer requirement in the 
national interest. 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 Christo '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. 
An advanced degree is any U.S. academic or professional degree or a foreign equivalent degree above 
that of a bachelor's degree.1 8 C.F.R. § 204.5(k)(2). A U.S. bachelor's degree or a foreign equivalent 
degree followed by five years of progressive experience in the specialty is the equivalent of a master's 
degree. Id. 
1 Profession shall include, but not be limited to, architects, engineers, lawyers, physicians, surgeons, and teachers in 
elementary or secondary schools, colleges, academics, or seminaries. Section 101(a)(32) of the Act. 
Exceptional ability means a degree of expertise significantly above that ordinarily encountered in the 
sciences, arts, or business. 8 C.F.R. § 204.5(k)(2). A petitioner must initially submit documentation 
that satisfies at least three of six categories of evidence: 
(A) An official academic record showing that the alien has a degree, diploma, 
certificate, or similar award from a college, university, school, or other 
institution of learning relating to the area of exceptional ability; 
(B) Evidence in the form of letter(s) from current or former employer(s) showing 
that the alien has at least ten years of full-time experience in the occupation 
for which he or she is being sought; 
(C) A license to practice the profession or certification for a particular profession 
or occupation; 
(D) Evidence that the alien has commanded a salary, or other renumeration for 
services, which demonstrates exceptional ability; 
(E) Evidence of membership in professional associations; or 
(F) Evidence of recognition for achievements and significant contributions to the 
industry or field by peers, governmental entities, or professional or business 
organizations. 
8 C.F.R. § 204.5(k)(3)(ii).2 
Where a petitioner meets these initial evidence requirements, we then consider the totality of the 
material provided in a final merits determination and assess whether the record shows that the 
petitioner is recognized as having a degree of expertise significantly above that ordinarily encountered 
in the field.3 See Kazarian v. USCIS, 596 F.3d 1115 (9th Cir. 2010) (discussing a two-part review 
where the documentation is first counted and then, if fulfilling the required number of criteria, 
considered in the context of a final merits determination); see also Visinscaia v. Beers, 4 F. Supp. 3d 
126, 131-32 (D.D.C. 2013); Rijal v. USCIS, 772 F. Supp. 2d 1339 (W.D. Wash. 2011). This two-step 
analysis is consistent with our holding that the "truth is to be determined not by the quantity of 
evidence alone but by its quality," as well as the principle that we examine "each piece of evidence 
for relevance, probative value, and credibility, both individually and within the context of the totality 
of the evidence, to determine whether the fact to be proven is probably true." Matter of Chawathe, 
25 l&N Dec. at 376. 
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. While neither the statute nor the pertinent regulations define the 
2 If these types of evidence do not readily apply to the individual's occupation , a petitioner may submit comparable 
evidence to establish eligibility. 8 C.F.R. § 204.5(k)(3)(iii). 
3 USCIS has previously confirmed the applicability of this two-part adjudicative approach in the context of individuals of 
exceptional ability. See generally 6 USCIS Policy Manual F.5(8)(2), https: //www.uscis.gov/policy-manual. 
2 
term "national interest," Matter of Dhanasar, 26 l&N Dec. 884, 889 (AAO 2016), provides the 
framework for adjudicating national interest waiver petitions. Dhanasar states that USCIS may, as 
matter of discretion,4 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. 
II. ANALYSIS 
The Petitioner proposes to establish a soccer development business for which he would work as its 
head soccer coach. The record shows that the Petitioner is a former professional soccer player who 
played in Brazil for several years, and more recently worked as a soccer administrative manager and 
soccer coach in Brazil. The Director's decision stated that the Petitioner established his eligibility for 
the underlying EB-2 classification as an advanced degree professional. However, the Director 
determined that the Petitioner did not establish that a waiver of the requirement of a job offer, and thus 
a labor certification, would be in the national interest. 
A. EB-2 Classification 
In determining the Petitioner met eligibility for the underlying EB-2 classification as an advanced 
degree professional, the Director did not provide an explanation for this decision. We will withdraw 
the Director's determination because the Petitioner did not claim eligibility as an advanced degree 
professional, instead claiming he is an individual of exceptional ability in the sciences, arts, or business 
under section 203(b)(2)(B)(i) of the Act. Also, the Director stated in arequest for evidence notice that 
the Petitioner established eligibility for the underlying classification and met five of the six initial 
evidentiary criteria under 8 C.F.R. § 204.5(k)(3)(ii) as an individual of exceptional ability. However, 
the record does not include the Director' s analysis of the evidence for the determination that the 
Petitioner met the five criteria. In addition, the record does not indicate that the Director considered a 
totality of the evidence in a final merits determination and assessed whether the Petitioner is 
recognized as having a degree of expertise significantly above that ordinarily encountered in the field 
of soccer coaching. 5 Upon de nova review, the Petitioner has not established he is an individual of 
exceptional ability in the sciences, arts, or business. 
To meet eligibility as an individual of exceptional ability, the Petitioner claimed to meet all six 
evidentiary criteria. For the reasons provided below, we conclude that the Petitioner does not meet 
the initial evidentiary requirements for classification as an individual of exceptional ability. 
4 See Flores v. Garland, 72 F.4th 85, 88 (5th Cir. 2023) Uoining the Ninth, Eleventh, and D.C. Circuit Courts (and Third 
Circuit Court in an unpublished decision) in concluding that USCIS' decision to grant or deny a national interest waiver 
to be discretionary in nature). 
5 See generally 6 USCIS Policy Manual, supra, at F.5(B)(2). 
3 
An official academic record showing that the individual has a degree, diploma, 
certificate, or similar award from a college, university, school, or other institution 
of learning relating to the area of exceptional ability. 8 C.F.R. § 204.5(k)(3)(ii)(A). 
The Petitioner submitted his high school academic transcript to meet this criterion. However, the 
Petitioner's high school transcript does not meet the plain language of the regulation. His high school 
transcript does not show that his high school degree is related to his area of exceptional ability, soccer 
coaching. Therefore, the Petitioner has not established he meets the requirements for the criterion. 
Evidence in the form of letter(s) from current or former employer(s) showing that 
the individual has at least ten years of full-time experience in the occupation for 
which he or she is being sought. 8 C.F.R. § 204.5(k)(3)(ii)(B). 
To meet this criterion, the Petitioner claims to have played professional soccer in Brazil for over 15 
years. He submitted astatement from the Union of Professional Football Athletes of thel II Iin Brazil acknowledging "[the Petitioner] as a professional 
soccer athlete, playing more than 15 years in the category." However, the statement does not meet the 
plain language of the criterion. The statement does not appear to be from the Petitioner's former 
employer(s), which his resume specifies as individual soccer clubs. Also, the statement indicates he 
has experience as aprofessional soccer player instead of as asoccer coach, the occupation being sought 
for in this petition. Because the evidence provided does not appear to be from his former employer(s) 
and does not demonstrate that he has at least ten years of full-time experience in his intended 
occupation as asoccer coach, the Petitioner has not established that he meets the plain language of the 
criterion. 
A license to practice the profession or certification for a particular profession or 
occupation. 8 C.F.R. § 204.5(k)(3)(ii)(C). 
To meet this criterion, the Petitioner submitted a "certificate of football monitor" issued to him by the 
Union of Professional Athletes of _____ The Petitioner also submitted an identity card 
issued by the Brazilian Association of Soccer Coaches for the Federative Republic of Brazil to the 
Petitioner. The identity card indicates he is a professional football coach having been a member of 
staff since 2022. However, the record does not include evidence explaining the significance of either 
document, nor does it indicate that either serves as a license or certification for the profession as a 
soccer coach. 
Because the record does not demonstrate that the Petitioner has a license to practice the profession or 
certification for his occupation, he has not established that he meets this criterion. 
Evidence that the individual has commanded a salary, or other renumeration for 
services, which demonstrates exceptional ability. 8 C.F.R. § 204.5(k)(3)(ii)(D). 
To meet this criterion, the Petitioner submitted astatement from an accountant listing the Petitioner's 
annual revenue for each of the years 2018 to 2022, and two articles relating to salaries of soccer players 
in Brazil. The regulation requires that the remuneration demonstrates the Petitioner's exceptional 
ability. However, the accountant's statement does not indicate that the Petitioner earned a salary or 
4 
renumeration for his exceptional ability as a soccer coach. For this reason, the Petitioner has not 
shown that he meets this criterion. 
Evidence of membership in professional associations. 8 C.F.R. § 204.5(k)(3)(ii)(E). 
The Petitioner submitted a membership certificate from International Coaches Association (ICA) 
indicating he is a "full member." The record does not include documentary evidence relating to the 
membership requirements for ICA or of ICA being aprofessional association under this criterion. The 
regulation at 8 C.F.R. § 204.5(k)(2) defines "profession" as "any occupation for which a United States 
baccalaureate degree or its foreign equivalent is minimum requirement for entry into the occupation." 
Accordingly, a professional association is one which requires its members to be members of a 
profession as defined in the regulation. The record does not show that ICA requires that its 
membership body be comprised of individuals who have earned a U.S. baccalaureate degree or its 
foreign equivalent, or that the organization otherwise constitutes a professional association. 
For the reasons explained above, the Petitioner does not meet this criterion. 
Evidence of recognition for achievements and significant contributions to the 
industry or field by peers, governmental entities, or professional or business 
organizations. 8 C.F.R. § 204.5(k)(3)(ii)(F). 
The Petitioner claims he meets this criterion based on his previous work as a professional soccer 
player. To support his claims, he submitted a recognition certificate, news articles, and 
recommendation letters attesting to his work as a professional soccer player. However, for this 
petition, the Petitioner intends to be a soccer coach instead of a soccer player. The record does not 
show that the Petitioner has been recognized for his achievements and significant contributions to his 
intended field of soccer coaching, as required under the criterion. Therefore, the Petitioner has not 
demonstrated he meets this criterion. 
The Petitioner has not established that he meets at least three of the evidentiary criteria at 8 C.F.R. 
§ 204.5(k)(3)(ii)(A) through (F). Because the Petitioner did not satisfy the initial evidence 
requirements, we need not conduct a final merits analysis to determine whether the evidence in its 
totality shows that he is recognized as having a degree of expertise significantly above that ordinarily 
encountered in the sciences, arts, or business. 8 C.F.R. § 204.5(k)(2). Nevertheless, we advise that 
we have reviewed the record in the aggregate and conclude that it does not support a finding that the 
Petitioner has established the recognition required for classification as an individual of exceptional 
ability. 
For the above stated reasons, we withdraw the Director's determination that the Petitioner is eligible 
for the underlying EB-2 classification. 
B. National Interest Waiver 
As discussed above, the Petitioner has not established his eligibility for the underlying EB-2 
classification, and therefore is not eligible for a waiver of that classification's job offer requirement. 
5 
However, we wi II discuss whether the Petitioner demonstrated a waiver of the labor certification would 
be in the national interest, the basis for the Director's decision. 
The Director found that while the Petitioner demonstrated the proposed endeavor has substantial merit, 
he did not establish that the proposed endeavor is of national importance, as required by the first prong 
of Dhanasar's analytical framework. The Director further found that the Petitioner did not establish 
that he is well positioned to advance the proposed endeavor, and 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. Upon 
de novo 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. 6 
The first prong of the Dhanasar framework, substantial merit and national importance, focuses on the 
specific endeavor that the individual proposes to undertake. The endeavor's merit may be 
demonstrated in a range of areas such as business, entrepreneurialism, science, technology, culture, 
health, or education. In determining whether the proposed endeavor has national importance, we 
consider its potential prospective impact. Matter of Dhanasar, 26 l&N Dec. at 889. 
The Petitioner proposes to establish a soccer development business for which he would be its head 
soccer coach. The Petitioner intends to establish the business in the I I Georgia area with plans 
to expand to four additional Georgia cities by its fifth year of business. The business plan indicates 
that the business would have soccer development classes for children, adolescents, professional and 
college soccer teams, and soccer athletes. In addition, the business will leverage the Petitioner's ability 
to "recognize potential talents" to create and coach a soccer team. The business plan states, "[t]he 
Petitioner endeavors to contribute to the overall skill level of soccer players in the [United States] by 
providing exceptional coaching sessions and programs for professional and college teams, as well as 
children and athletes, positively influencing society by promoting sports and active lifestyles." The 
Petitioner intends to "help aspiring players develop essential and core skills in soccer and generally 
enhance their overall athleticism." The business plan explains that he plans "to create and implement 
age-appropriate training plans" which would "benefit the professional and amateur soccer players 
.... " We agree with the Director that the Petitioner's endeavor has substantial merit. 
With respect to national importance, the Director determined "the Petitioner has not established that 
the proposed work has implications beyond adding to the pool of knowledge in the field, and therefore 
impact the [s]occer field or the United States at a level sufficient to demonstrate the national 
importance of the proposed endeavor." The Director further found that the record did not demonstrate 
the Petitioner's proposed endeavor "has the potential to create a significant economic impact or have 
broader implications" as contemplated by Dhanasar. Therefore, the Director determined the 
Petitioner did not establish his proposed endeavor is of national importance. Upon de novo review, 
the Petitioner has not established that his proposed endeavor satisfies the national importance element 
of Dhanasar 's first prong, as discussed below. 
At the outset, the Petitioner argues on appeal that the Director incorrectly analyzed the evidence. He 
questions whether the Director considered the evidence claiming that although the decision lists the 
Petitioner's evidence, the Director provided "a vague and nonspecific decision" without addressing 
6 While we may not discuss every document submitted, we have reviewed and considered each one. 
6 
the content of the evidence. The Petitioner maintains that the evidence submitted validates "his 
contribution to the world of soccer similar to how Lionel Messi intends to do so." The Petitioner then 
argues on appeal that the Director did not consider the totality of the evidence in the denial decision 
and failed to identify the evidence's deficiencies. He stresses the amount of documentary evidence, 
claiming that the Director's decision did not reference any of the documents submitted with the initial 
petition or with the reply to a request for evidence notice. Arguing that the Director did not explain 
specific reasons for the decision to deny the petition, the Petitioner maintains he could not understand 
why the evidence failed to satisfy the burden of proof. We disagree with the Petitioner's claims 
relating to the deficiencies of the Director's denial decision. 
Contrary to the Petitioner's arguments, the decision properly analyzed the Petitioner's documentation 
and weighed the evidence to evaluate the Petitioner's eligibility by a preponderance of the evidence. 
In addition to acknowledging the evidence submitted, the Director provided a reasoned analysis of 
specific documents to explain how they did not show the national importance of the Petitioner's 
proposed endeavor. The standard of proof in this proceeding is 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 l&N Dec. at 375-76. To determine whether a petitioner has met the burden 
under the 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). 
On appeal, the Petitioner mainly highlights his success as a professional soccer player to show the 
national importance of his proposed endeavor. He argues that his "national importance is best shown 
through the impact that he has already had on the nation of Brazil. There is substantial [sic] amount 
of evidence demonstrating how [the Petitioner's] influence has positively affected both communities 
and organizations to the benefit of the culture and economy." The Petitioner details his 
accomplishments as a professional soccer player in Brazil relying on recommendation letters from 
teams he previously played with in Brazil. He stresses his player statistics, the recognition he received 
from his former teams as a soccer player, and the impact he had on his teams and the country of Brazil 
as a professional soccer player. With the appeal he submits additional news articles highlighting that 
a team he played with was promoted to a higher soccer division and the economic importance of the 
team's promotion. 
However, the Petitioner's reliance on his professional experience, achievements, and credentials to 
establish the national importance of his proposed endeavor is misplaced. His professional experience, 
achievements, and credentials relate to the second prong of the Dhanasar framework, which "shifts 
the focus from the proposed endeavor to the foreign national." Matter of Dhanasar, 26 l&N Dec. at 
890. The issue here is whether the specific endeavor that the Petitioner proposes to undertake has 
national importance under Dhanasar 's first prong. To evaluate whether the Petitioner's proposed 
endeavor satisfies the national importance requirement, we look to evidence documenting the 
"potential prospective impact" of his work. Id. at 889. 
The Petitioner argues on appeal that his exceptional ability as a soccer player will contribute to the 
U.S. soccer industry as a soccer coach. As a coach, he would transfer his knowledge attained during 
his soccer career to U.S. soccer players. 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 
7 
field more broadly. Id. at 893. Here, the record lacks evidence showing that the Petitioner transferring 
his soccer knowledge to soccer players will reach beyond the players he would directly worki with to 
impact the field more broadly. The Petitioner also argues that his work as asoccer coach would "have 
broader implications" as attested by public officials and authorities in the recommendation letters. He 
points out that the recommendation letters attest to his ability as a soccer player and the positive 
exposure he brought to the teams he played with which benefited local communities and economies. 
He argues that as a former professional soccer player who influenced local communities, he has the 
potential to impact his business' regional economy. To support his claims, he compares his potential 
impact to other well-known professional soccer players, David Beckham and Leo Messi, and how they 
economically influenced the soccer industry and local communities. However, the Petitioner's claims 
and recommendation letters relate to the impact of his work as asoccer player, instead of his proposed 
endeavor as a soccer coach. 
Similar to Dhanasar, the record does not demonstrate that the Petitioner's proposed work to provide 
soccer instruction and development classes to soccer players would impact the soccer industry more 
broadly. In Dhanasar, we stated "[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. The evidence does not 
suggest that the Petitioner's soccer development business would impact the soccer and soccer coaching 
fields more broadly. 
The record includes the Petitioner's business plan, which describes the business' potential "national­
level impact." The business plan claims the business would have economic, health, and social welfare 
benefits. The plan stresses the recent growth of the soccer industry in the United States and its 
expected increase in revenue due to the United States hosting games for the 2026 Fl FA World Cup. 
The business plan maintains that the Petitioner's soccer development business would generate 
economic and employment benefits through the creation of jobs; support the development of soccer 
in the United States; provide soccer development and coaching services that are in demand; provide 
educational opportunities for athletes; transfer the Petitioner's soccer skill knowledge to athletes; help 
crime prevention because increased sports participation leads to lower crime; help athletes cope with 
mental health issues; and support U.S. government initiatives related to sports, fitness, and nutrition. 
The business plan also describes the Petitioner's professional experience; his ownership of the 
business; the business' services and intended clients; the demand for the business' services; a market 
analysis of the sports coaching industry; and the business' projected marketing, staffing, and financial 
forecasts. 
However, the Petitioner has not provided corroborating evidence to support his claims that his 
business' activities stand to provide substantial economic, health, and societal welfare benefits to areas 
of Georgia and the United States. The Petitioner's general claims that his soccer development business 
will benefit the local Georgia and U.S. economies and will provide the claimed health and societal 
welfare benefits has not been established through independent and objective evidence. The 
Petitioner's statements are not sufficient to demonstrate his endeavor has the potential to provide 
economic, health, and societal welfare benefits to Georgia and the United States. The Petitioner must 
support his assertions with relevant, probative, and credible evidence. See Matter of Chawathe, 25 
l&N Dec. at 376. Without documentary evidence that his proposed job duties as head soccer coach 
for his soccer development business would impact the soccer industry more broadly, rather than 
8 
benefiting his business and his proposed clients, the Petitioner has not demonstrated by a 
preponderance of the evidence that his proposed endeavor is of national importance. 
The business plan also indicates that the business is expected to stimulate the U.S. economy by creating 
new jobs and generating payroll tax revenue. The business plan projects that in five years the business 
will hire eight direct employees, create 19 indirect jobs, and generate almost $100,000 in tax revenue. 
However, the record 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 his business' future staffing levels and business activities 
stand to provide substantial economic benefits to communities in Georgia or the United States. While 
the Petitioner expresses his desire to contribute to the United States and his local community in 
Georgia, he has not established with specific, probative evidence that his endeavor will have broader 
implications in the soccer and soccer coaching fields, will have significant potential to employ U.S. 
workers, or will have other substantial positive economic effects in Georgia or the United States. The 
Petitioner must support his assertions with relevant, probative, and credible evidence. See id. Even if 
we were to assume everything the Petitioner claims will happen, the record lacks evidence showing 
that creating eight direct jobs and 19 indirect jobs, and generating almost $100,000 in tax revenue over 
a five-year period rises to the level of national importance. 
The record also includes industry reports and articles to demonstrate the national importance of his 
proposed endeavor. The reports and articles relate to the effects of stress on the body and coping with 
stress; the positive outlook for soccer in the United States; the necessary skills for youth soccer 
coaches; the impact of professional soccer player, Lionel Messi, joining the American team, Inter 
Miami; the importance of skilled immigrants to the U.S. economy; labor shortages in the United States 
and the need for entrepreneurs; venues for the FIFA World Cup in 2026; increased popularity of soccer 
in the United States; economic benefits to countries hosting the FIFA World Cup; importance of sports 
to a country's culture and social welfare; and the expected impact of President Biden's presidency on 
arts and culture. 
We recognize the importance of the soccer industry and related careers, and the significant 
contributions from immigrants who have become successful entrepreneurs; however, merely working 
in the soccer coaching field or starting a soccer development business 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 l&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. We also stated 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. The industry 
reports and articles submitted do not discuss any projected U.S. economic impact or job creation 
specifically attributable to the Petitioner's proposed endeavor. 
We further note that the record includes an opinion from a lecturer atl Iin New Jersey. 
The opinion provides an analysis of the national importance of the Petitioner's proposed endeavor 
concluding, "the United States would greatly benefit from the expertise and skills of an experienced 
Soccer Coach/CEO such as [the Petitioner], who has extensive knowledge and expertise in sports 
9 
training. His work has both substantial merit and national importance." In support of the Petitioner's 
proposed endeavor having national importance, the opinion explains the demand for soccer coaches 
and trainers due to the increased popularity of soccer in the United States. In addition, the opinion 
indicates that because the Petitioner's endeavor would be an outdoor physical activity, it would benefit 
the players' mental and physical health. The opinion provides a general summary of the economic 
benefits of physical activity; the revenue generated through spectator sports; the cultural benefits of 
sports; and government initiatives promoting physical activity to reduce diseases and obesity. 
However, the opinion's focus on the benefits of sports and physical activity does not demonstrate that 
the Petitioner's specific endeavor may have a prospective impact in his field. Although the opinion 
mentions the Petitioner's proposed endeavor, it does not specify how the Petitioner's work as a soccer 
coach for his soccer development business would have a potential prospective impact on the U.S. 
economy or in the field of his proposed endeavor. Simply stating that he is qualified to be a soccer 
coach who would promote individual health through outdoor physical activity and enhance cultural 
enrichment through team soccer is not sufficient to meet the "national importance" requirement under 
the Dhanasar framework. 
The Petitioner has not demonstrated that his proposed endeavor extends beyond his business and his 
future clients to impact the field of soccer or any other industries or the U.S. economy more broadly 
at a level commensurate with national importance. Beyond general assertions, he has not 
demonstrated that the work he proposes to undertake as the owner and head soccer coach of his 
proposed soccer development business offers innovations that would contribute to advancements in 
his industry or otherwise has broader implications for his field. The economic, health, and societal 
welfare benefits that the Petitioner claims depend on numerous factors, and the Petitioner did not offer 
a sufficiently direct evidentiary tie between his proposed work and the claimed economic, health, and 
societal welfare benefits. 
Because the documentation in the record does not sufficiently establish the national importance of the 
Petitioner's proposed endeavor as required by the first prong of the Dhanasar precedent decision, he 
has not demonstrated eligibility for a national interest waiver. Because the identified basis for denial 
is dispositive of the Petitioner's appeal, we decline to reach and hereby reserve the Petitioner's 
appellate arguments regarding his eligibility under the second and third prongs. 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). 
Ill. CONCLUSION 
The Petitioner has not established eligibility for the underlying EB-2 immigrant classification. Also, 
the Petitioner has not met the requisite first prong of the Dhanasar analytical framework. Therefore, 
10 
the Petitioner has not established eligibility for a national interest waiver as a matter of discretion. 
The appeal will be dismissed for the above stated reasons. 
ORDER: The appeal is dismissed. 
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