dismissed H-1B Case: Business Consulting

U.S. Citizenship 
and Immigration 
Services 
In Re: 9452840 
Appeal of Vermont Service Center Decision 
Form 1-129, Petition for a Nonimmigrant Worker (H-1B) 
Non-Precedent Decision of the 
Administrative Appeals Office 
Date : FEB. 17, 2021 
The Petitioner seeks to temporarily employ the Beneficiary as a "consultant" under the H-lB 
nonimmigrant classification for specialty occupations. See Immigration and Nationality Act (the Act) 
section 101(a)(15)(H)(i)(b), 8 U.S.C. § 1101(a)(15)(H)(i)(b). The H-1B program allows a U.S. 
employer to temporarily employ a qualified foreign worker in a position that requires both: (a) the 
theoretical and practical application of a body of highly specialized knowledge; and (b) the attainment 
of a bachelor's or higher degree in the specific specialty ( or its equivalent) as a minimum prerequisite 
for entry into the position. 
The Director of the Vermont Service Center denied the petition, concluding that the record did not 
establish that the proffered position qualifies as a specialty occupation. On appeal, the Petitioner 
asserts that the Director erred in the decision. 
The Petitioner bears the burden of proof to demonstrate eligibility by a preponderance of the evidence. 1 
We review the questions in this matter de nova. 2 Upon de nova review, we will dismiss the appeal. 
I. SPECIAL TY OCCUPATION 
A. Legal Framework 
Section 101(a)(l5)(H)(i)(b) of the Act defines an H-lB nonimmigrant as a foreign national "who is 
coming temporarily to the United States to perform services ... in a specialty occupation described in 
section 214(i)( 1) ... " ( emphasis added). Section 214(i)(l) of the Act, 8 U.S.C. § 1 l 84(i)(l), defines the 
term "specialty occupation" as an occupation that requires "theoretical and practical application of a 
body of highly specialized knowledge, and attainment of a bachelor's or higher degree in the specific 
specialty (or its equivalent) as a minimum for entry into the occupation in the United States." The 
regulation at 8 C.F .R. § 214.2(h)(4)(ii) largely restates section 214(i)(l) of the Act but adds a 
non-exhaustive list of fields of endeavor. In addition, 8 C.F.R. § 214.2(h)(4)(iii)(A) provides that the 
1 Matter ofChawathe, 25 I&N Dec. 369,375 (AAO 2010). 
2 See Matter of Christo 's Inc., 26 I&N Dec. 537, 537 n.2 (AAO 2015) . 
proffered position must meet one of four criteria to qualify as a specialty occupation position. 3 Lastly, 
8 C.F.R. § 214.2(h)(4)(i)(A)(]) states that an H-lB classification may be granted to a foreign national 
who "will perform services in a specialty occupation ... " ( emphasis added). 
Accordingly, to determine whether the Beneficiary will be employed in a specialty occupation, we 
look to the record to ascertain the services the Beneficiary will perform and whether such services 
require the theoretical and practical application of a body of highly specialized knowledge attained 
through at least a bachelor's degree or higher in a specific specialty or its equivalent. Without 
sufficient evidence regarding the duties the Beneficiary will perform, we are unable to determine whether 
the Beneficiary will be employed in an occupation that meets the statutory and regulatory definitions of 
a specialty occupation and a position that also satisfies at least one of the criteria at 8 C.F.R. 
§ 2 l 4.2(h)( 4)(iii)(A). The services the Beneficiary will perform in the position determine: (1) the normal 
minimum educational requirement for entry into the particular position, which is the focus of criterion 
1; (2) industry positions which are parallel to the proffered position and thus appropriate for review 
for a common degree requirement, under the first alternate prong of criterion 2; (3) the level of 
complexity or uniqueness of the proffered position, which is the focus of the second alternate prong 
of criterion 2; ( 4) the factual justification for a petitioner normally requiring a degree or its equivalent, 
when that is an issue under criterion 3; and ( 5) the degree of specialization and complexity of the 
specific duties, which is the focus of criterion 4. 8 C.F.R. § 214.2(h)(4)(iii)(A). 
By regulation, the Director is charged with determining whether the petition involves a specialty 
occupation as defined in section 214(i)(l) of the Act. 8 C.F.R. § 214.2(h)(4)(i)(B)(2). The Director 
may request additional evidence in the course of making this determination. 8 C.F.R. § 103.2(b)(8). 
In addition, a petitioner must establish eligibility at the time of filing the petition and must continue to 
be eligible through adjudication. 8 C.F.R. § 103.2(b)(l). 
B. Analysis 
The Petitioner is a global business strategy consulting firm that provides services in corporate strategy 
and organization, cost & supply chain management, customer strategy & marketing, growth strategy, 
mergers & acquisitions, performance improvement, information & technology management, and 
private equity. It states that it helps make the big decisions on strategy, organization, operations, 
technology, and mergers & acquisitions, and that its job is to help executives make the best decisions 
about their most critical business issues, including corporate strategy, business unit strategy, and 
strategy across the organization, including sales and marketing, operations, IT, overall organizational 
effectiveness and change management. 
Upon review of the Petitioner's description of the proposed duties of the position the duties described 
are broad and described with minimal context. 4 Even when considering the details, the Petitioner 
included in its response to the Director's request for evidence (RFE), the record lacks sufficient 
3 8 C.F.R. § 214.2(h)(4)(iii)(A) must be read with the statutory and regulatory definitions ofa specialty occupation under 
section 214(i)(l) of the Act and 8 C.F.R. § 214.2(h)(4)(ii). We construe the term "degree" to mean not just any 
baccalaureate or higher degree, but one in a specific specialty that is directly related to the proposed position. See Royal 
Siam Co1p. v. Chertoff, 484 F.3d 139, 147 (1st Cir. 2007) (describing "a degree requirement in a specific specialty" as 
"one that relates directly to the duties and responsibilities of a pmiicular position"). 
4 We have reviewed the descriptions of duties in full but will not repeat them here for the sake of brevity. 
2 
information and context to understand what the Beneficiary will be expected to do in the position . For 
example, the Petitioner states the Beneficiary will "[t]ake ownership and responsibility for assigned 
work streams related to the development, design and implementation of corporate business strategies, 
functional capabilities and enhanced client performance" and will "[u]ilize expertise to formulate cost 
reduction; customer retention; process re-engineering; organizational design and effectiveness; market 
analysis, branding and definition; quality management; strategic acquisition and divestiture." The 
Petitioner does not detail particular projects /work streams and does not define "expertise ." The 
additional narrative does not clarify the tasks . It appears from the broadly stated duties that the 
Beneficiary needs at most a general business degree, 5 not a bachelor's degree in a specific specialty, 
to perform the duties described. These duties without specific context are generic that, while they may 
appear (in some instances) to comprise the duties of a specialty occupation, are not sufficiently 
described to demonstrate the actual services the Beneficiary will provide to the Petitioner on behalf of 
its clients . 
The Petitioner also indicates that the Beneficiary will spend 20 percent of his time traveling to client 
sites to establish needs and present recommendations but does not describe how a degree in a specific 
specialty would provide the knowledge required to perform these non-specific tasks . Without specific 
discussion of what the Beneficiary will be expected to do within the context of the services the 
Petitioner provides to its clients, the descriptions do not demonstrate that a bachelor's degree in a 
specific specialty , or its equivalent, would be required to perform the duties of the position . The 
descriptions are insufficient to satisfy the statutory and regulatory definitions of specialty occupation. 
As noted , both definitions require the Petitioner to demonstrate that the proffered position requires: 
(1) the theoretical and practical application of a body of highly specialized knowledge; and (2) the 
attainment of a bachelor's degree in the specific specialty. It is not possible to ascertain the body of 
highly specialized knowledge required to perform the duties and how such a body of highly specialized 
knowledge is directly related to the position and is attained through a specialized degree . 
Additionally , the Petitioner's minimum requirements to perform the position do not assist in 
establishing that the proffered position actually requires a bachelor's degree or higher in a specific 
specialty, or its equivalent. The Petitioner states that it requires the individual in the proffered position 
of "consultant" to possess a master's degree, or the equivalent, in business administration or a related 
field (MBA). The Petitioner then provides an alternative to this requirement, as it also indicates that 
it will accept "a substantially completed academic program towards [an MBA] plus a Bachelor's 
5 The agency has longstanding concerns regarding general-purpose bachelor 's degrees in business administration with no 
additional specialization . For exampl e, in Matter of Ling , 13 I. & N. Dec. 35 (Reg'! Comm 'r 1968), the agency stated that 
attainment of a bachelor 's degree in business administration alone was insufficient to qualify a foreign national as a 
member of the professions pursuant to section 101(a)(32) of the Act, 8 U.S.C. § 1101(a)(32) . Twenty years later, the 
agency looked to the nature of the position itself and clarified that a requirement for a degree with a generali zed title, such 
as busine ss administration , without further specification , was insufficient to qualify the position as one that is professional 
pursuant to section 10l(a)(32) of the Act. Michael Hertz Assocs., 19 I&N Dec. at 560. See also Matter of Caron Int '!, 
Inc., 19 I&N Dec. 791 (Comm 'r 1988) (vice president for manufacturing in a textile company was not a professional 
position because individual holding general degree in business , engin eering or science could perform its duties). The 
agency 's concerns regarding a general-purpose , non-specific degree in business, or business administration , continued 
under the revamped H-lB program . See, e.g., Shanti, Inc. v. Reno, 36 F. Supp. 2d 1151 (D. Minn. 1999); Royal Siam, 484 
F.3d at 147; 2233 Paradis e Road, LLC v. Cissna, No. 17-cv- 01018- APG- VCF, 2018 WL 3312967 (D. Nev., July 3, 
2018); XiaoTong Liu v. Baran , No. 18-00376-JVS , 2018 WL 7348851 (C.D. Cal., Dec. 21, 2018); Parzenn Partners v. 
Baran, No. 19-cv-11515-ADB , 2019 WL 6130678 (D. Mass., Nov . 19, 2019). 
3 
degree, or the equivalent, in a directly related field such as Economics or a related quantitatively 
analytical field." The Petitioner does not define the term "quantitatively analytical field" and does not 
provide examples of specific quantitative or analytical degrees that would be required to perform the 
position and are directly related to the position. Thus, we cannot ascertain the number of fields the 
Petitioner would find acceptable for the position and accordingly, cannot determine what specific body 
of highly specialized knowledge attained through such specialized degrees is directly related to the 
position. 
In response to the Director's RFE, the Petitioner adds that it will accept a bachelor's degree or 
equivalent "in a field that directly relates to our practice areas," plus a substantially completed 
academic program towards an MBA, in lieu of a completed MBA. The Petitioner adds farther that an 
"individual's academic program in Business Administration 6 must include specialized courses which 
directly relate to the management consulting services [it] provides." The Petitioner, however, does 
not define the practice areas to which the Beneficiary will be assigned and does not identify the specific 
specialized courses or specific concentration within a business administration degree that directly 
relate to the consulting services it provides. 7 These broad statements, without more, are insufficient 
to establish that the particular position proffered here requires a bachelor's degree, or higher, in a 
specific specialty. We also note that the Petitioner's apparent acceptance of this Beneficiary to 
perform the tasks of the proffered position casts farther doubt on the Petitioner's actual minimum 
requirements for the particular position. 8 Again, the lack of a focused description of the proposed 
duties within the context in which the Beneficiary will perform his duties does not establish that the 
particular position here requires anything more than a general bachelor's degree. Without such detail 
and context, the record does not include the requisite evidence to evaluate the Beneficiary's role and 
responsibility within the Petitioner's business operations and most importantly to evaluate the 
requirements to perform the duties described. 
On appeal, the Petitioner repeats the previously s~eneral requirements and refers to a 
1
osition 
evaluation authored byl I, l__J College! 11 opines 
that "it would be impossible to handle the required job duties of the Consultant position with [the 
Petitioner] without at least a bachelor's degree in Economics or a related field and a partially 
completed 9 Master of Business Administration."~----~ also claims that the nature of the job 
duties of the proffered position requires a highly specialized degree in the technical areas of market 
6 The Petitioner does not clarify if the academic program is in pursuit of a bachelor's degree or a master's degree. 
7 For example, the position appears to broadly relate to corporate strategy and organization, customer strategy and 
marketing, however, the duties are not sufficiently developed to conclude that these are the practice areas to which the 
Beneficiary would be assigned, rather than for example, mergers and acquisitions or supply chain management which 
would appear to require a different set of courses. 
8 The Beneficiary in this matter did not have a master's degree when the petition was filed and thus did not qualify under 
the Petitioner's first alternative requirement for employment. Notably, the Beneficiary's three-year foreign degree was 
evaluated to be three years of study toward a U.S. bachelor's degree in business administration, not economics, the 
Petitioner's stated preference for the underlying bachelor's degree. The record does not include evidence demonstrating 
that the Beneficiary's foreign general studies are the equivalent of a U.S. bachelor's degree in economics. Even a 
bachelor's degree in business administration, as opposed to three-years of study toward a bachelor's degree, is a degree in 
a field of general applicability. As noted above, a general business degree, without more, is insufficient to establish a 
P,Osition is a specialty occupation. 
91 lcloes not explain what constitutes a "partially completed" MBA and how a partially completed degree is 
the equivalent of one that is substantially completed, as is required by the Petitioner. 
4 
analysis, statistical analysis, quantitative modeling, business strategy development, and project 
management. He reiterates that only individuals with post-secondary degrees with educational 
foundations in Economics or related fields could handle these technical areas and then states that "a 
bachelor's-level educational foundation in a highly analytical field is required to handle the varied and 
complex job duties of the proposed position; an individual who lacks at least a bachelor's degree in a 
suitable analytical, stratewc field would be unable to handle the requisite duties of the position." 
Althougbl does not clearly define what constitutes related fields, he appears to expand 
the acceptable degree fields to perform the position from an educational foundation in economics to 
those of other undefined suitable analytical, strategic fields. There are any number of degrees that are 
related only through general quantitative, analytical underpinnings. Such a wide variety of degree 
fields is not sufficiently finite to conclude that such a wide range of fields imparts a "body of highly 
specialized knowledge" attained by a bachelor's degree in a specific specialty, or its equivalent. 
We also considered the evaluation authored b~ I Professor of Finance at the College of 
Business Administration at the University I I I I finds that the proffered 
position emphasizes quantitative and analytical skills, problem solving ability, project 
planning/management capabilities, and computing knowledge. We note that these skills may be 
attained through study in a variety of disparate degrees. I I finds farther that the proffered 
position involves a heavy focus upon performing management analysis, applying analytical 
conclusions, meeting project requirements and requires in-depth knowledge of business 
administration. Again, there is insufficient analysis of these concepts to determine that they would 
require more than a general degree in business, or its equivalent. 
Also on appeal, the Petitioner refers to the hiring practices of its direct competitors as set out in a letter 
submitted in response to the Director's RFE. The author of that letter notes that on the basis of their 
understanding of the industry and the job duties of management consultants, it is common industry 
practice for top-tier management consulting firms to "require at least a bachelor's degree in business 
administration, economics, finance or a related field" and that an MBA is typically required for more 
senior consultants. However, if the common industry standard is to accept a bachelor's degree in 
business administration, a degree of general applicability, then the standard strongly suggests such a 
position is not a specialty occupation. 10 
We have considered the Petitioner's arguments on appeal that courts "have routinely rejected the 
position that in order to qualify as a specialty occupation for H-lB visa purposes, the degree must be 
in only one specific academic major or have a specific title," and its citation to Residential Finance 
Corp. v. USCIS, 839 F. Supp. 2d 985 (S.D. Ohio 2012) in support of that proposition. 11 The court 
stated in Residential Finance that "[t]he knowledge and not the title of the degree is what is 
important. Diplomas rarely come bearing occupation-specific majors." Id. at 997. 
We agree with both the Petitioner and with this principle stated by the judge in Residential Finance. 12 
Here, however, the Petitioner does not provide a comprehensive list of the underlying bachelor's 
10 Royal Siam, 484 F.3d at 147. 
11 The Petitioner also cites to Next Generation Tech., Inc. v. Johnson, 328 F. Supp. 3d 252, 267 (S.D.N.Y. 2017) and RELX, 
Inc. v. Baran, 397 F.Supp.3d 41 (D.D.C. Aug. 5, 2019) for similar propositions. 
12 As the Petitioner acknowledges, provided the specialties are closely related, e.g., chemistry and biochemistry, a 
5 
degree-fields that meet its minimum requirements, it provides only the aforementioned degree in 
economics and fields that qualify under its "quantitative and analytical" standard. 13 Numerous 
unrelated specialties would appear to fall within the Petitioner's "quantitative and analytical" range: 
for example, it would appear as though a bachelor's degree in any non-humanities field might qualify 
an individual to perform the duties of the proffered position. 14 The current record of proceeding does 
not establish how this wide, far-ranging, and divergent range of degrees could form either a body of 
highly specialized knowledge or a specific specialty. 15 We therefore cannot conclude that the 
proffered position requires anything more than a general bachelor's degree. The Petitioner has 
satisfied neither the statutory definition of a "specialty occupation" at section 214(i)(l)(B) of the Act 
nor the regulatory definition of a specialty occupation at 8 C.F.R. § 214.2(h)(4)(ii). 
As the Petitioner has not met the threshold requirement of satisfying the statutory and regulatory 
definitions of the term "specialty occupation," it cannot satisfy any of the supplemental 
specialty-occupation criteria enumerated at 8 C.F.R. § 214.2(h)(4)(iii)(A)(l)-(4) because, again, we 
must consider those criteria in harmony with the thrust of the related regulatory provisions and with 
the statute as a whole. In other words, we must construe those criteria' s references to the term "degree" 
as meaning not just any baccalaureate or higher degree, but one in a specific specialty that is directly 
related to the proffered position. 16 For example, the Petitioner cannot satisfy the supplemental 
specialty-occupation criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A)(]) because even if it establishes, in the 
words of this criterion, that "a baccalaureate or higher degree or its equivalent is normally the 
minimum requirement for entry into the particular position," we would still construe the term "degree" 
to mean not just any baccalaureate or higher degree, but one in a specific specialty that is directly 
related to the proffered position. And as discussed above, the Petitioner would not be able to make 
that demonstration. 
The same will be true of the remaining three criteria at 8 C.F.R. § 214.2(h)(4)(iii)(A)(2)-(4): because 
minimum of a bachelor's or higher degree in more than one specialty is recognized as satisfying the "degree in the specific 
specialty ( or its equivalent)" requirement of section 214(i)(l )(B) of the Act. In such a case, the required "body of highly 
specialized knowledge" would essentially be the same. Since there must be a close correlation between the required "body 
of highly specialized knowledge" and the position, however, a minimum entry requirement of a degree in two disparate 
fields, such as philosophy and engineering, would not meet the statutory requirement that the degree be "in the specific 
specialty ( or its equivalent)," unless the Petitioner establishes how each field is directly related to the duties and 
responsibilities of the particular position. Section 214(i)( I )(B) of the Act ( emphasis added). 
13 The Petitioner refers to its recruitment at various ivy league universities and provides website information regarding its 
recruitment efforts. However, the Petitioner's standards for its consultant position is non-specific extending to "an 
ambitious business school graduate, advanced degree holder or working professional." As the Petitioner does not require 
any specific degree. then we question how the position involves a "highly specialized body of knowledge" or requires a 
bachelor's degree, or the equivalent, in a "specific specialty." The Petitioner has not adequately explained or supported 
its standards for determining what degree or degree fields are required for the consultant position or even this particular 
consultant position. 
14 Moreover, depending upon the specific coursework undertaken while obtaining the degree, certain fields within the 
humanities might also fall within the Petitioner's stated range. 
15 "A position that requires applicants to have any bachelor's degree, or a bachelor's degree in a large subset of fields, can 
hardly be considered specialized." Caremax, Inc. v. Holder, 40 F.Supp.3d 1182, 1187-88 (N.D. Cal. 2014) 
16 Royal Siam, 484 F.3d at 147; Caremax, 40 F.Supp.3d at 1187-88; Innova Sols., Inc. v. Baran, 338 F. Supp. 3d 1009, 
1017 (N.D. Cal. 2018) (USCTS did not abuse its discretion in reading the degree requirement together with the "specific 
specialty" language); Pa}joy v. Cuccinelli, No. l 9-cv-03977-HSG, 2019 WL 3207839 at *3 (N.D. Cal. July 17. 2019) 
(statutory and regulatory text appear to supp01i USCIS's interpretation that the degree requirement must be read in 
conjunction with the "specific specialty" requirement). 
6 
the Petitioner does not require a bachelor's degree in a spec[fic specialty, or the equivalent, it will not 
be able to satisfy any of those criteria because we will interpret each reference to a "degree" to mean 
not just any baccalaureate or higher degree, but one in a specific specialty that is directly related to the 
proffered position. We therefore will not consider the Petitioner's arguments, and the evidence it 
submits, in support of its contention that it satisfies the supplemental specialty-occupation criteria 
enumerated at 8 C.F.R. § 214.2(h)(4)(iii)(A)(])-(4). 
The record of proceeding does not establish that the proffered position requires both: ( 1) the theoretical 
and practical application of a body of highly specialized knowledge; and (2) the attainment of a 
bachelor's degree in the specific specialty. The Petitioner, therefore, has satisfied neither the statutory 
definition of a "specialty occupation" at section 214(i)(l)(B) of the Act nor the regulatory definition 
of a specialty occupation at 8 C.F .R. § 214.2(h)( 4)(ii). As the Petitioner had not satisfied that threshold 
requirement, it cannot satisfy any of the supplemental specialty-occupation criteria enumerated at 
8 C.F.R. § 214.2(h)(4)(iii)(A)(])-(4). The Petitioner, therefore, has not established that the proffered 
position is a specialty occupation. 
II. BENEFICIARY'S QUALIFICATIONS 
We also note that the record contains an additional basis for ineligibility that the Director did not 
address. As described above, the Petitioner in this matter identifies two acceptable ways to enter into 
the position proffered here. It requires a master's degree in business administration; or, a substantially 
completed academic program towards a master's degree in business administration plus a bachelor's 
degree, or the equivalent, in a directly related field such as economics or a related quantitatively 
analytical field. The Beneficiary here did not have a master's degree in business administration when 
the petition was filed. Accordingly, the Beneficiary did not qualify for the proffered position under 
the Petitioner's own first identifiable standard. The record also does not include evidence that the 
Beneficiary qualified to perform the position pursuant to the Petitioner's second standard to enter the 
proffered position. 
The Beneficiary in this matter has a three-year foreign degree that has been evaluated by a credential 
evaluation service as "the equivalent of three years of academic studies toward a Bachelor of Business 
Administration Degree at an accredited US college or university." The Beneficiary also had completed 
three semesters of academic study in business administration at a U.S. university when the petition 
was filed. The first year of study included 22 courses, all but 4 at the 400-course level, indicative of 
study at a senior or fourth year of study in a bachelor's degree program. The credential evaluation 
service determined that the Beneficiary's foreign degree and the academic studies completed at a U.S. 
university fulfilled the equivalent of at least a bachelor's-level degree in business administration. 17 
The credential evaluation service states that it is "a credentials evaluation service and academic 
advisory firm specializing in the evaluation of foreign educational credentials." Thus, the record does 
not establish that they specialize in evaluating U.S. studies. Further, a credential evaluation service 
appears limited to evaluating foreign academic studies. 18 8 C.F.R. § 214.2(h)(4)(iii)(D). In this matter 
17 Even ifwe accepted the credential evaluation service's evaluation of the U.S. academic studies, the Beneficiaiy would 
only have a education equivalent to a U.S. bachelor's degree in business administration when the petition was filed. 
18 Moreover, the record also does not establish that the Beneficiary's qualifications met the Petitioner's own stated 
requirements when the petition was filed. The Petitioner claims that the bachelor's degree (underlying the master's degree 
7 
the record also does not include sufficient evidence so that U.S. Citizenship and Immigration Services 
may conclude through its own review that the Beneficiary had attained the equivalent of a bachelor's 
degree in a specific specialty when the petition was filed. 8 C.F.R. § 214.2(h)(4)(iii)(D)(5). The 
current record does not establish that the Beneficiary was qualified under the Petitioner's own 
standards when the petition was filed. 
III. CONCLUSION 
The appeal will be dismissed for the above stated reasons. In visa petition proceedings, it is the 
petitioner's burden to establish eligibility for the immigration benefit sought. Section 291 of the Act, 
8 U.S.C. § 1361. The Petitioner has not met that burden. 
ORDER: The appeal is dismissed. 
in business administration) must be "in a directly related field such as Economics or a related quantitatively analytical 
field." However, the record does not include probative evidence that the Beneficiaiy has a bachelor's degree in economics 
or a related quantitatively analytical field. Rather he has a foreign degree that has been evaluated to be the U.S. equivalent 
of three years of study toward a general bachelor's degree in business administration. 
8