dismissed H-1B Case: Computer Science

MATTER OF N-, INC. 
Non-Precedent Decision of the 
Administrative Appeals Office 
DATE: MAY 31,2016 
APPEAL OF CALIFORNIA SERVICE CENTER DECISION 
PETITION: FORM I-129, PETITION FOR A NONIMMIGRANT WORKER 
The Petitioner, a computer company, seeks to temporarily employ the Beneficiary as an 
"Applications Systems Engineer" under the H-IB nonimmigrant classification for specialty 
occupations. See . Immigration and Nationality Act (the Act) § 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, California Service Center, revoked the approval of the petition. The Director 
concluded that the statement of facts contained in the approved petition was not true and correct 
pursuant to 8 C.F.R. § 214.2(h)(11)(iii)(A)(2). 
The matter is now before us on appeal. In its appeal, the Petitioner asserts that the Director's 
conclusion is erroneous. 
Upon de novo review, the appeal will be dismissed. 
I. REVOCATION 
A. Legal Framework 
U.S. Citizenship and Immigration Services (USCIS) may revoke the approval of an H-1B petition 
pursuant to 8 C.F.R. § 214.2(h)(11)(iii), which states the following: 
(A) Grounds for revocation. The director shall send to the petitioner a notice of 
intent to revoke the petition in relevant part if he or she finds that: 
(I) The beneficiary is no longer employed by the petitioner in the capacity 
specified in the petition, or if the beneficiary is no longer receiving 
training as specified in the petition; or 
Matter. of N-, Inc. 
(2) The statement of facts contained in the petition or on the application for a 
temporary labor certification was not true and correct, inaccurate, 
fraudulent, or misrepresented a material fact; or 
(3) The petitioner violated terms and conditions of the approved petition; or 
( 4) The petitioner violated requirements of section 1 01 (a)( 15)(H) of the Act or 
paragraph (h) of this section; or 
(5) The approval of the petition violated paragraph (h) of this section or 
involved gross error. 
B. Analysis 
Upon review of the record, we determine that the Director properly revoked the approval of the 
petition pursuant to 8 C.F.R. § 214.2(h)(11)(iii)(A)(2): the statement of facts contained in the 
petition was not true and correct. 
On the Form I-129, the Petitioner represented that it has 23 current employees in the United States. 
On the Form I-129, H-1B and H-1B1 Data Collection and Filing Fee Exemption Supplement, the 
Petitioner represented that it has a total of 25 or fewer full-time equivalent employees in the United 
States. The Petitioner also represented that it was eligible to pay the lower fee ($750) mandated by 
the American Competitiveness and Workforce Improvement Act (ACWIA) based on its number of 
employees. The Petitioner signed both forms under the penalty of perjury, certifying that all the 
information contained therein was true and correct to the best of its knowledge. 
In its notice of intent to revoke (NOIR) the approval of the petition, the Director advised the 
Petitioner that she had obtained evidence indicating that the Petitioner employed 30 U.S. employees 
at the time the Form 1-129 was filed. In response to the NOIR, the Petitioner explained that it had 
relied upon its February 2015, payroll, which was the last available payroll, in order to prepare and 
file the petition in March 2015. The Petitioner attested in an affidavit that it had 23 employees in 
February 2015, and thus, its number of employees on the Form I -129 was not untrue and incorrect. 
We find that the Director's revocation of the approval was proper. The Petitioner's explanations are 
neither reasonable, nor supported by objective, credible evidence. In essence, the Petitioner is 
asserting that it was unaware of its true number of employees as of March 2015, when the petition 
was prepared and filed. However, as pointed out by the Director, that information should have been 
available to the Petitioner as the purported employer of these individuals. Moreover, the Petitioner 
asserts that the actual number of employees increased because "[s]ome employees joined the 
petitioner in the month of March 2015." However, the Petitioner did not explain why it did not 
. account for these newly-joined employees on the Form I-129. In other words, the Petitioner has not 
established that its decision to rely upon its February payroll was reasonable, given its knowledge 
that new employees had joined the company in March. 
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Matter of N-, Inc. 
Notably, the Petitioner's List of Active Employees does not indicate that any employees joined the 
company in March 2015, thus undermining the Petitioner's explanation.
1 
In addition, this list 
contains the names and information of 33 current employees- all of whom had joined the company 
prior to March 2015? This information further undermines the credibility of the Petitioner's 
explanation, e.g., that it only had 23 employees in February 2015. 
We thus find that the statement of facts contained in the petition was not true and correct, and that 
the Director properly revoked the approval of the petition pursuant to 8 C.P.R. 
§ 214.2(h)(11 )(iii)(A)(2). 
II. SPECIALTY OCCUPATION 
We will also address another additional, independent ground, not identified by the Director's notice 
of revocation, that could also warrant initiation of revocation proceedings at the discretion of the 
Director. Specifically, we find that the evidence of record is insufficient to establish that the 
proffered position qualifies as a specialty occupation, and thus, that the approval of the petition 
violated paragraph (h) of this section or involved gross error. 8 C.P.R. § 214.2(h)(11)(iii)(A)(5). 
A. Legal Framework 
Section 214(i)(l) of the Act, 8 U.S.C. § 1184(i)(l), defines the term "specialty occupation" as an 
occupation that requires: 
(A) theoretical and practical application of a body of highly specialized knowledge, 
and 
(B) 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.P.R.§ 214.2(h)(4)(ii) states, in pertinent part, the following: 
Specialty occupation means an occupation which [(1 )] requires theoretical and 
practical application of a body of highly specialized knowledge in fields of human 
endeavor including, but not limited to, architecture, engineering, mathematics, 
physical sciences, social sciences, medicine and health, education, business 
specialties, accounting, law, theology, and the arts, and which [(2)] requires the 
attainment of a bachelor's degree or higher in a specific specialty, or its equivalent, as 
a minimum for entry into the occupation in the United States. 
1 
The list contains a total of34 employees. Only one individual joined the company after March 2015. 
2 
These 33 employees include one employee who the Petitioner indicated was on extended leave in India. Even without 
this individual, the Petitioner had at least 32 active employees in March 2015. 
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Matter of N-, Inc. 
Pursuant to 8 C.F.R. § 214.2(h)(4)(iii)(A), to quality as a specialty occupation, a proposed position must 
meet one of the following criteria: 
(1) A baccalaureate or higher degree or its equivalent is normally the minimum 
requirement for entry into the particular position; 
(2) The degree requirement is common to the industry in parallel positions among 
. similar organizations or, in the alternative, an employer may show that its 
particular position is so complex or unique that it can be performed only by an 
individual with a degree; 
(3) The employer normally requires a degree or its equivalent for the position; or 
( 4) The nature of the specific duties [is] so specialized and complex that knowledge 
required to perform the duties is usually associated with the attainment of a 
baccalaureate or higher degree. 
As a threshold issue, it is noted that 8 C.F .R. § 214.2(h)( 4 )(iii)(A) must logically be read together 
with section 214(i)(l) of the Act and 8 C.F.R. § 214.2{h)(4)(ii). In other words, this regulatory 
language must be construed in harmony with the thrust of the related provisions and with the statute 
as a whole. SeeK Mart Corp. v. Cartier, Inc., 486 U.S. 281, 291 (1988) (holding that construction 
oflanguage which takes into account the design of the statute as a whole is preferred); see also COlT 
Independence Joint Venture v. Fed. Sav. and Loan Ins. Corp., 489 U.S. 561 (1989); Matter o.fW-F-, 
21 I&N Dec. 503 (BIA 1996). As such, the criteria stated in 8 C.F.R. § 214.2(h)(4)(iii)(A) should 
logically be read as being necessary but not necessarily sufficient to meet the statutory and 
regulatory definition of specialty occupation. To otherwise interpret this section as stating the 
necessary and sufficient conditions for meeting the definition of specialty occupation would result in 
particular positions meeting a condition under 8 C.F.R. § 214.2(h)( 4)(iii)(A) but not the statutory or 
regulatory definition. See Defensor v. Meissner, 201 F.3d 384, 387 (5th Cir. 2000). To avoid this 
result, 8 C.F.R. § 214.2(h)(4)(iii)(A) must therefore be read as providing supplemental criteria that 
must be met in accordance with, and not as alternatives to, the statutory and regulatory definitions of 
specialty occupation. 
As such and consonant with section 214(i)(l) of the Act and the regulation at 8 C.F .R. 
§ 214.2(h)(4)(ii), U.S. Citizenship and Immigration Services (USCIS) consistently interprets the 
term "degree" in the criteria at 8 C.F.R. § 214.2(h)(4)(iii)(A) to mean not just any baccalaureate or 
higher degree, but one in a specific specialty that is directly related to the proffered position. See 
Royal Siam Corp. 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 particular 
position"). Applying this standard, USCIS regularly approves H-lB petitions for qualified 
individuals who are to be employed as engineers, computer scientists, certified public accountants, 
college professors, and other such occupations. These professions, for which petitioners have 
regularly been able to establish a minimum entry requirement in the United States of a baccalaureate 
or higher degree in a specific specialty, or its equivalent, directly related to the duties and 
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(b)(6)
Matter of N-, Inc. 
responsibilities of the particular position, fairly represent the types of specialty occupations that 
Congress contemplated when it created the H-1B visa category. 
To determine whether a particular job qualifies as a specialty occupation, USCIS does not simply 
rely on a position's title. The specific duties of the proffered position, combined with the nature of 
the petitioning entity's business operations, are factors to be considered. USCIS must examine the 
ultimate employment of the individual, and determine whether the position qualifies as a specialty 
occupation. See generally Defensor v. Meissner, 201 F. 3d 384. The critical element is not the title 
of the position or an employer's self-imposed standards, but whether the position actually requires 
the theoretical and practical application of a body of highly specialized knowledge, and the 
attainment of a baccalaureate or higher degree in the specific specialty as the minimum for entry into 
the occupation, as required by the Act. 
We note that, as recognized by the court in Defensor, 201 F.3d at 387-88, where the work is to be 
performed for entities other than the petitioner, evidence of the client companies' job requirements is 
critical. See Defensor v. Meissner, 201 F.3d at 387-88. The court held that the former Immigration 
and Naturalization Service had reasonably interpreted the statute and regulations as requiring the 
· petitioner to produce evidence that a proffered position qualifies as a specialty occupation on the 
basis of the requirements imposed by the entities using the beneficiary's services. !d. Such evidence 
must be sufficiently detailed to demonstrate the type and educational level of highly specialized 
knowledge in a specific discipline that is necessary to perform that particular work. 
B. The Proffered Position 
According to the Form I-129, the Petitioner seeks to employ the Beneficiary as an "Applications 
Systems Engineer" from October 1, 2015, to July 19, 2018. The Petitioner indicated that the 
Beneficiary will work off-site in Michigan. 
The labor condition application (LCA) submitted to support the visa petition states that the proffered 
position corresponds to Standard Occupational Classification (SOC) code and occupation title 
15-1121, "Computer Systems Analysts," from the Occupational Information Network (O*NET). 
The LCA further states that the proffered position is a Level I 
position. The LCA lists the sole place 
of employment as the Michigan address. 
In its cover letter, the Petitioner stated that the Beneficiary will work out of the worksite of its 
"direct-client," whose office is located in Michigan. The Petitioner listed the 
duties of the proffered position as follows (verbatim): 
• Engineering, design, and evaluation of new and current production application 
systems and supporting infrastructure 
• Operational .planning, design and implementation for new and updated programs, 
inclusive of effectively utilizing tier partners 
• Systems analysis and support for Internet-based solutions 
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(b)(6)
Matter of N-, Inc. 
• Provide extensive troubleshooting and technical expertise in identifying issues 
that impact service delivery 
• Provide comprehensive troubleshooting and recommend fixes for application 
issues, including batch jobs, data store, application functionality and presentation 
layers 
• Provide design requirements, feedback and guidance to software development 
teams for operational best practices 
• Analysis, stability and support of a specific subset Expedia productions systems 
• Operational support as application SME for 24x7 systems, including on call 
rotation duties 
• Utilizing your enterprise technical expertise to drive the improvements of 
production systems 
• Utilizing your support expertise to set and improve existing standards for system 
administration, such as process, builds, monitoring, reporting and documentation. 
In support of the petition, the Petitioner submitted an Employment Agreement it executed with the 
Beneficiary which provides the following description of duties (verbatim):3 
[The Beneficiary] will be responsible for Core Development of the Credit Engine in 
the project ASAP. It includes development of both web layer and business Layer for 
the credit module using JSP's, EJB's, DAO's, JMS and Struts Framework and 
deployment of the application on WebLogic.Production and QA support for the 
developed components including bug fixing and enhancements.Creating clustered 
Weblogic domains and deploying all the modules of the application and integrating 
all the modules. Deploying · and integrating every release in Onsite 
environments.Written ant scripts for creating clustered domains and deploying all the 
modules.Automating the process of build and deployment using ant and also involved 
in the development of Automatic Patch Process for using Java and Ant. 
C. Analysis 
As a preliminary matter, we find that the record of proceedings does not contain sufficient evidence 
establishing the minimum educational requirement for the proffered position. There is no 
documentation directly from the end-client specifying its educational requirement for the position; 
the Assigned Personnel Form simply describes the "Hiring Requirements" as "Application Systems 
Engineer." Despite the Petitioner's claim that the contract signed between the end-client and the 
Petitioner confirms a "Bachelor's degree requirement," the contract does not contain any provisions 
regarding the minimum educational requirement for assigned personnel. "[G]oing on record without 
supporting documentary evidence is not sufficient for purposes of meeting the burden of proof in 
3 The Petitioner subsequently submitted an "amended" Employment Agreement in response to the Director's NOIR 
which noted several impermissible provisions relating to the LCA in the original Employment Agreement. Both 
Employment Agreements contain virtually the same description of duties. 
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(b)(6)
Matter of N-, Inc. 
these proceedings." Matter of So.ffici, 22 I&N Dec. 158, 165 (Comm'r 1998) (citing Matter of 
Treasure Craft ofCal., 14 I&N Dec. 190 (Reg'l Comm'r 1972)). 
Even if the contract did indicate that a bachelor's degree is required, as claimed by the Petitioner, the 
mere requirement of a general bachelor's degree, without more, would be inadequate to establish 
that a position qualifies as a specialty occupation.4 A petitioner must demonstrate that the proffered 
position requires a precise and specific course of study that relates directly and closely to the 
position in question. There must be a close correlation between the required specialized studies and 
the position; thus, the mere requirement of a degree, without further specification, does not establish 
the position as a specialty occupation. Cf Matter of Michael Hertz Assocs., 19 I&N Dec. 558, 560 
(Comm'r 1988) ("The mere requirement of a college degree for the sake of general education, or to 
obtain what an employer perceives to be a higher caliber employee, also does not establish 
eligibility."). Thus, while a general-purpose bachelor's degree may be a legitimate prerequisite for a 
particular position, requiring such a degree, without more, will not justify a finding that a particular 
position qualifies for classification as a specialty occupation. Royal Siam Corp. v. Chertoff, 484 
F.3d at 147. 
Moreover, it also cannot be found that the proffered position qualifies as a specialty occupation 
because the Petitioner has not credibly and sufficiently demonstrated the substantive nature of the 
proffered position. 5 
The evidence of record contains generalized, broad descriptions of the work to be performed by the 
Beneficiary. For instance, the Assigned Personnel Form signed by the Petitioner and the end-client 
simply describes the "Services to be performed" as "Design, Coding and unit testing core 
components and client customization of the product." No further details about these job duties or 
what "product" the Beneficiary will work on was provided in the Assigned Personnel Form. Nor 
does the record of proceedings contain any other documentation directly from the end-client 
verifying and describing the terms of the Beneficiary's assignment. 
Notably, the evidence of record does not contain any detailed explanation about what project(s) the 
Beneficiary will be assigned to work for the end-client, such as the nature, complexity, and length of 
this particular project. Equally, if not more, significant is that the Petitioner has indicated that the 
Beneficiary will be assigned to various projects at different end-clients. More specifically, the 
Petitioner's description of the proffered position contains the duty of "[a]nalysis, stability and 
support of a specific subset productions systems." In addition, the Employment Agreement 
states that the Beneficiary "will be responsible for Core Development of the Credit Engine in the 
4 The Petitioner also indicated that the Beneficiary is qualified for the position by virtue of his educational qualifications. 
However, the test to establish a position as a specialty occupation is not the skill set or education of a proposed 
beneficiary, but whether the position itself qualifies as a specialty occupation. 
5 
The California Secretary of State website indicates that the Petitioner's corporate status has been suspended. That is, 
the Petitioner's powers, rights and privileges, including the right to use its corporate name in California, were suspended. 
See attached print-outs. The Petitioner's corporate status raises questions regarding whether the Petitioner's offer of 
employment to the Beneficiary is bonafide. 
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(b)(6)
Matter of N-, Inc. 
project and will also be "involved in the development of Automatic Patch Process for 
The Petitioner has not explained how these references to "Credit Engine in the project 
and · relate to the end-client project. The Petitioner has not submitted sufficient 
objective documentation establishing exactly what project(s) the Beneficiary will work on, and for 
whom. 
"[I]t is incumbent upon the petitiOner to resolve the inconsistencies by independent objective 
evidence." Matter of Ho, 19 I&N Dec. 582, 591 (BIA 1988). Any attempt to explain or reconcile 
such inconsistencies will not suffice unless the petitioner submits competent objective evidence 
pointing to where the truth lies. !d. at 591-92. "Doubt cast on any aspect of the petitioner's proof 
may, of course, lead to a reevaluation of the reliability and sufficiency of the remaining evidence 
offered in support of the visa petition." !d. at 591. 
The Petitioner states that the Beneficiary will serve as a subject matter expert or "SME" for certain 
systems. In contrast, the Petitioner designated the proffered position as a Level I (entry) position.6 
In designating the proffered position at a Level I wage rate, the Petitioner has indicated that the 
proffered position is a comparatively low, entry-level position relative to others within the 
occupation. 7 That is, in accordance with the relevant DOL explanatory information on wage levels, 
this wage rate indicates that the Beneficiary is only required to have a basic understanding of the 
occupation and will perform routine tasks that require limited, if any, exercise of judgment. See U.S. 
Dep't of Labor, Emp't & Training Admin., Prevailing Wage Determination Policy Guidance, 
Nonagric. Immigration Programs (rev. Nov. 2009), available at 
http://www.foreignlaborcert.doleta.gov/pdf/NPWHC _Guidance_ Revised _11_ 2009 .pdf The 
6 A Level I wage rate is described as follows: 
Levell (entry) wage rates are assigned to job offers for beginning level employees who have 
only a basic understanding of the occupation. These employees perform routine tasks that require 
limited, if any, exercise of judgment. The tasks provide experience and familiarization with the 
employer's methods, practices, and programs. The employees may perform higher level work for 
training and developmental purposes. These employees work under close supervision and receive 
specific instructions on required tasks and resul~s expected. Their work is closely monitored and 
reviewed for accuracy. Statements that the job offer is for a research fellow, a worker in training, or an 
internship are indicators that a Level I wage should be considered. 
See U.S. Dep't of Labor, Emp't & Training Admin., Prevailing Wage Determination Policy Guidance, Nonagric. 
Immigration Programs (rev. Nov. 2009), available at 
http:/ /www.foreignlaborcert.doleta.gov/pdf/NPWHC _Guidance_ Revised _11_ 2009 .pdf 
7 The Petitioner's designation of this position as a Level I, entry-level position undermines its claim that the position is a 
higher-level position compared to other positions within the same occupation. Nevertheless, a Level I wage-designation 
does not preclude a proffered position from classification as a specialty occupation, just as a Level IV wage-designation 
does not definitively establish such a classification. In certain occupations (e.g., doctors or lawyers), a Level I, entry­
level position would still require a minimum of a bachelor's degree in a specific specialty, or its equivalent, for 
entry. Similarly, however, a Level IV wage-designation would not reflect that an occupation qualifies as a specialty 
occupation if that higher-level position does not have an entry requirement of at least a bachelor's degree in a specific 
specialty, or its equivalent. That is, a position's wage level designation may be a relevant factor but is not itself 
conclusive evidence that a proffered position meets the requirements of section 214(i)(l) of the Act. 
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Matter of N-, Inc. 
Petitioner's designation of the proffered position as a Level I, entry-level position is inconsistent 
with this stated job duty, and further precludes an understanding the substantive nature of the 
proffered position. 
The evidence of record contains other vague statements by the Petitioner and the end-client 
regarding the Beneficiary's actual job duties and work location. For instance, the Assigned 
Personnel Form lists the Beneficiary's "Primary work location" as the end-client's Michigan 
premises. The use of the word "Primary" denotes that the Beneficiary may also be assigned ·to 
perform work at other, unspecified locations. In addition, the Petitioner stated in its cover letter that 
"[t]he petitioner has enough resources and financial strength to continue paying the beneficiary even 
without specific project/s," and that "[i]f required, the petitioner can place the beneficiary in place of 
any one of those contractor positions" which are "sourced through third party companies. 8 Likewise, 
the Petitioner's Employment Agreements with the Beneficiary contain provisions indicating that the 
Beneficiary may be assigned to perform undisclosed work, such as that the Beneficiary's "duties 
shall be rendered at [Petitioner's] business premises or at such other places as the [Petitioner] may 
require" and that he "shall also perform such other duties in the ordinary course of business as 
performed by other persons in similar such positions, as well as such other reasonable duties as may 
be assigned from time to time by the [Petitioner]." When considered as a whole, the evidence of 
record lacks a sufficient, detailed explanation of all the work the Beneficiary will be assigned to 
perform during the entire validity period requested, including the location(s) of such work, the end­
client(s) involved, and the specific job duties to be performed. 
Finally, we note that the Assigned Personnel Form misspells the Beneficiary's name and lists his 
end-date as October 12, 2018, even though the Petitioner requested a validity period ending on July 
19, 2018. 9 The Petitioner's Employment Agreements also misspell the Beneficiary's name. We 
thus must question whether there exists a legally binding contract between the Beneficiary and the 
Petitioner, as well as between the Petitioner and the end-Client utilizing the Beneficiary's services, as 
claimed. 
For all of the above reasons, we find the evidence of record insufficient to demonstrate the 
substantive nature of the proffered position and its constituent duties. Consequently, the evidence of 
record does not demonstrate the proffered position satisfies · any criterion at 8 C.F .R. 
§ 214.2(h)(4)(iii)(A), because it is the substantive nature of the proffered position that determines (1) the 
normal minimum educational requirement for 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 
8 The Petitioner states that it has a direct contractual relationship with the end-client, thus indicating that there are no 
third-party or vendor companies involved. 
9 
The Petitioner did not request the maximum three years for the Beneficiary's duration of stay, which would have ended 
on September 30, 2018. 
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Matter of N-, Inc. 
issue under criterion 3; and (5) the degree of specialization and complexity of the specific duties, which 
is the focus of criterion 4. 
As the evidence of record is insufficient to establish that the proffered position qualifies as a 
specialty occupation, it would have been within the scope of the Director's authority to initiate 
revocation-on-notice proceedings regarding this issue upon proper notice to the Petitioner of her 
intent to do so. 
III. CONCLUSION 
Upon review of the record, we determine that the Director properly revoked the approval of the 
petition pursuant to 8 C.F.R. § 214.2(h)(ll)(iii)(A)(2). The petition will remain revoked and the 
appeal dismissed. 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; Matter ofOtiende, 26 I&N 
Dec. 127, 128 (BIA 2013) (citing Matter of Brantigan, 11 I&N Dec. 493, 495 (BIA 1966)). Here, 
that burden has not been met. 
ORDER: The appeal is dismissed. 
Cite as Matter ofN-, Inc., ID# 17016 (AAO May 31, 2016) 
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