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 a "SAP 
consultant" under the H-1B 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-lB 
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, denied the petition. The Director concluded that the 
evidence of record is insufficient to establish that: (1) the proffered position qualifies as a specialty 
occupation; (2) the Beneficiary is qualified to serve in a specialty occupation position in accordance 
with the applicable statutory and regulatory provisions; and (3) the labor condition application 
supports the petition. 
The matter is now before us on appeal. In its appeal, the Petitioner asserts that the Director's 
conclusions are erroneous. 
Upon de novo review, the appeal will be dismissed. 
I. SPECIALTY OCCUPATION 
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. 
Matter of N-, Inc. 
The regulation at 8 C.F.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. 
Pursuant to 8 C.F.R. § 214.2(h)(4)(iii)(A), to qualify 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 
of language 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 ofW-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. 
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Matter of N-, Inc . 
. 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 
responsibilities of the particular position, fairly represent the types of specialty occupations that 
Congress contemplated when it created the H-lB 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 notthe 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. Id. 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 
On the Form I-129, Petition for a Nonimmigrant Worker, the Petitioner described itself as a 22-
employee software services company located in California. The Petitioner seeks to 
employ the Beneficiary as a "SAP consultant" from October 1, 2015, to July 23, 2018, at a salary of 
$63,000 per year. 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). 
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Matter of N-, Inc. 
The LCA further states that the proffered position is a Level II position. The LCA lists the sole 
place of employment as the Michigan address. 
In its cover letter, the Petitioner stated that the Beneficiary "will be designated to primarily work at 
[the Petitioner's] End-Client's business premises located [in] MI This 
assignment is based on [the Petitioner's] direct contract with [the End-Client]." The Petitioner 
provided a description of the proffered position, which was later broken down into percentages of 
time in response to the Director's request for evidence (RFE), as follows (verbatim): 
Tasks Difficulty %Time 
Level to be 
Spent 
1. Responsible for working with the SAP team Planning and 
establishing after go-live activities including ongoing application 3 10% 
support. 
2. Working on End-to-end Implementation, Upgrades, Installations, 
Configurations, Post-Installation Activities, OS/DB Migration, 4 20% 
Performance Tuning, Documentation, Defining SLA, Transition, and 
Managing Delivery of all SAP. 
3. Proactively identifying issues that may negatively impact a projects 
deliverables. 3 10% 
4. Participating in 24*7 Support of applications and translating business 
requirements into technical requirements and implementing the 4 10% 
solution. 
5. Performing analysis, definition, creation and implementation of 
technical application standards and documentation. 3 5% 
6. Managing the delivery of SAP OS/DB migrations from one hardware 
platform to another within defined time and adhered to quality 4 20% 
standards. 
7. Participating in Proof of Concept Development, HANA administration 
and monitoring, HANA revision and SPS upgrade, HANA studio and 4 10% 
client installations, Monitoring of SAP HANA database from HANA 
studio and OS level commands, Performance monitoring for SAP 
HANA studio and Performance tuning, 
8. Activating and deactivating services usmg SAP HANA studio, 
Performing OS Migration of the Entire R3, BI, PI Landscape from 4 10% 
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Matter of N-, Inc. 
HP-UX to Linux Environment, Handling Runtime issues during the 
Export and Import and Upgrade, 
9. Monitoring the systems from the SAP Solution Manager, Configuring 
the OSS settings, and Coordinating with off-shore Basis Support 4 5% 
Team. 
Notes on Difficulty Level 
1 Novice 
2 Some Exposure 
3 Familiarity with Computers 
4 Bachelor's 
5 Master's 
In support of the petition, the Petitioner submitted an "Assigned Personnel Form" which describes 
the "Services to be performed" as "Design, Coding and unit testing core components and client 
customization of the product." The Petitioner also submitted a letter from the end-client stating that 
the Beneficiary will work at its business premises in Michigan "as an SAP Consultant for the project 
entitled The end-client letter lists job duties similar to those listed in the 
Petitioner's cover letter and RFE response. 
Furthermore, the Petitioner submitted an Employment Agreement with the Beneficiary which 
contains a lengthy description of duties, as cited below in part (verbatim): 
[The Beneficiary] will be responsible for Gathering the security requirements in 
Preparation Phase with touch base with Customer. Prepared the Security blue print 
according to the customer requirements and policies.Interacting with the customer 
during realization phase.Created Project team roles and provided access to Project 
team based on the equipment.Prepared Role Matrix by gathering the requirements 
from BPDDs and FTDS Created Business and end user roles through BRM in GRC 
10.0 Performed Unit testing of roles and transported them to Production Handled 
User &role administration using ARM & BRM in GRC 1 O.O.Configured MSMP 
work flow for ARM and BRM in Access Control.Prepared the end users access and 
trained them based on their functionality. Built the SOD Rule set as per customer 
business specifications and uploaded them to production. Performed the risk analysis 
for roles and users using ARA in GRC 10.0 Creation of users and roles based on 
Customer predefined process Resolving authorization issues for Project team and also 
end users. Performed security testing during SIT2 and made the security section 
ready as part of preparation phase. Configured de-centralized functionality EAM in 
GRC Supported the SAP Implementation team during go-live Resolved Access and 
authorization issues during post go-live is a Global leader in 
automobile sector with operations world wide.In the Latin America, Africa, Middle 
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Matter of N-, Inc. 
Project/Customer: basis administration 
and Health checks.User administration and Authorization support .... 
C. Analysis 
As a preliminary matter, the evidence of record does not consistently demonstrate the proffered 
position's minimum entry requirement. The end-client asserts that it requires a minimum of a 
bachelor's degree in "Computer Science, Computer Applications, Information Technology, 
Mathematics, Business or a closely related field." The Petitioner has variously stated that it requires 
a minimum of a bachelor's degree in "Computer Science, Computer Engineering, Computer 
Information Systems, Information Technology, or any field of Engineering or related field," and that 
"the position of SAP Consultant require[ s] a minimum educational qualification of a baccalaureate 
degree in Business, Computer Science, Math, Engineering, Information Technology, Accounting, or 
related field." 1 It is therefore not clear whether the minimum entry requirement for the proffered 
position can be satisfied by bachelor's degrees in "Business," "Accounting," and "any field of 
Engineering." 
If the proffered position can be satisfied by a degree in business, this indicates that the proposed 
position does not qualify as a specialty occupation. A petitioner niust demonstrate that the proffered 
position requires a precise and specific course of study that relates directly and closely to the 
position in question. Since there must be a close correlation between the required specialized studies 
and the position, the requirement of a degree with a generalized title, such as "Business," 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). 
To prove that a job requires the theoretical and practical application of a body of highly specialized 
knowledge as required by section 214(i)(l) of the Act, a petitioner must establish that the position 
requires the attainment of a bachelor's or higher degree in a specialized field of study or its 
equivalent. As discussed supra, USCIS interprets the degree requirement at 8 C.F.R. 
§ 214.2(h)( 4 )(iii)(A) to require a degree in a specific specialty that is directly related to the proposed 
pos1t1on. Although a general-purpose business 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. Cherto.ff, 484 
F.3d at 147.2 Without more, a degree requirement in "Business," alone, indicates that the proffered 
1 The Petitioner submitted vacancy announcements for positions it claims are similar to the proffered position, some of 
which also allow degrees in "Business," "Business Adm.," and "Bachelor's Degrees with an emphasis on ... business, 
or accounting." . 
2 
Specifically, the United States Court of Appeals for the First Circuit explained in Royal Siam that: 
The courts and the agency consistently have stated that, although a general-purpose bachelor's degree, 
such as a business administration degree, may be a legitimate prerequisite for a particular position, 
requiring such a degree, without more, will not justifY the granting of a petition for an H-1 B specialty 
occupation visa. See, e.g., Tapis Int'lv. INS, 94 F.Supp.2d 172, 175-76 (D. Mass. 2000); Shanti, 36 F. 
Supp. 2d at 1164-66; cf Matter of Michael Hertz Assocs., 19 l&N Dec. 558, 560 ([Comm'r] 1988) 
(b)(6)
Matter of N-, Inc. 
position is not in fact a specialty occupation. 
If the proffered position can be satisfied by a degree in accounting, this also indicates that the 
proffered position does not qualify as a specialty occupation. In general, provided the specialties are 
closely related, e.g., computer science and information technology, a 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 computer science 
and accounting, 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 such that the required "body of highly 
specialized knowledge" is essentially an amalgamation of these different specialties. Section 
214(i)(l)(B) of the Act (emphasis added). The Petitioner has not done so here. 
Thus, based on the stated educational requirements, we cannot find that the proffered position 
qualifies as a specialty occupation. Moreover, we cannot find 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.3 
The evidence of record does not contain a detailed explanation of the project, 
such as the nature, complexity, and length of this particular project. In addition, the job duties are 
not specifically explained within the context of the project. Instead, the 
evidence of record contains generalized, duplicative, and inconsistent 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 by the Beneficiary as "Design, Coding and unit testing core 
components and client customization of the product."4 No further details about these job duties or 
about what "product" the Beneficiary will work on were provided in this form. The Assigned 
Personnel Form does not contain any references to any particular project(s) for the end-client. 
!d. 
(providing frequently cited analysis in connection with a conceptually similar provision). This is as it 
should be: elsewise, an employer could ensure the granting of a specialty occupation visa petition by 
the simple expedient of creating a generic (and essentially artificial) degree requirement. 
3 
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. 
4 
This form lists the Beneficiary's end-date as October 12, 2018, even though the Petitioner requested a validity period 
ending on July 23, 2018. The Petitioner did not request the maximum three years, which would have ended on 
September 30, 2018. 
(b)(6)
Matter of N-, Inc. 
The end-client letter states that the Beneficiary will be working on the project, 
but it also does not provide any additional information and explanation about this particular project. 
Furthermore, the end-client letter (which contains substantially the same job duties as found in the 
Petitioner's cover letter and RFE response) describes the proffered duties in broad and generalized 
terms that do not adequately convey the specific tasks to be performed. To illustrate, the Beneficiary 
will purportedly be "[r]esponsible for working with the SAP team" and "[p ]Ianning and establishing 
after go-live 
activities including ongoing application support." However, there is no further 
explanation of what specific tasks the Beneficiary will perform (e.g., what is meant by the vague 
phrases "[r]esponsible for working with" and "application support"), nor is there any further 
explanation of what specific ''application" the Beneficiary will be supporting. As another example, 
the Petitioner has not elaborated upon what specific tasks or applications are involved in the duty of 
"[p]articipating in 24*7 Support of applications." Notably, the end-client letter does not expressly 
contain any job duties involving "Design, Coding and unit testing," which are the duties stated in 
the 
Assigned Personnel Form. 
The evidence of record contains other inconsistencies regarding the proffered duties as well. In 
particular, the Petitioner's Employment Agreement with the Beneficiary describes the proffered job 
duties as including ' is a Global leader in automobile sector with operations 
world wide.In the Latin America, Africa, Middle Project/Customer: 
The Petitioner has not explained the meaning of this particular duty, and the relationship 
(if any) between the end-client, and the Petitioner. The Petitioner's Employment 
Agreement also. contains repeated references to among other undefined terms and 
acronyms. The Petitioner has not explained what is, and how it relates to the ' 
project. "[G]oing on record without supporting documentary evidence is not sufficient 
for purposes of meeting the burden of proof in these proceedings." Matter of Soffici, 22 I&N Dec. 
158, 165 (Comm'r 1998) (citing Matter a/Treasure Craft o.fCal., 14 I&N Dec. 190 (Reg'l Comm'r 
1972)). We note that many ofthe proffered duties listed in the Employment Agreements are worded 
in the past tense. This, along with the unexplained references to and 
other undefined terms and acronyms, lead us to question the credibility of this document. 
"[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. 
5 While petitioner-provided job duties are generally outside the scope of consideration for establishing whether the 
position qualifies as a specialty occupation, we are considering the Petitioner's descriptions of the duties here for the 
purpose of highlighting the inconsistencies and deficiencies in the evidence of record. See Defensor v. Meissner, 20 I 
F.3d at 387-88 (stating that the petitioner-provided job duties and alleged requirements to perform those duties were 
irrelevant to a specialty occupation determination where the nurses in that case would provide services to the end-client 
hospitals and not to the petitioning staffing company). · 
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Matter of N-, Inc. 
The evidence of record contains other vague statements by the Petitioner and the end-client 
regarding the Beneficiary's "primary" work duties and location that further lead us to question the 
nature of the proffered position. The Assigned Personnel Form lists the Beneficiary's "Primary 
work location" as the end-client's Michigan premises. The Petitioner also states in its cover letter 
that the Beneficiary "will be designated to primarily work at [the Petitioner's] End-Client's business 
premises." However, the use of the words "primary" or "primarily" denotes that the Beneficiary 
may also be assigned to perform work at other, unspecified locations, and that she may be assigned 
to perform job duties other than those disclosed in the petition. The Petitioner's Employment 
Agreement with the Beneficiary contains other similar 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 and the specific job duties to 
be performed. 
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, we are 
precluded from finding that the proffered position satisfies any criterion at 8 C.F.R. 
§ 214.2(h)(4)(iii)(A), because it is the substantive nature of that work 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 
issue under criterion 3; and ( 5) the degree of specialization and complexity of the specific duties, which 
is the focus of criterion 4. Accordingly, as the evidence does not satisfy any of the criteria at 8 C.F.R. 
§ 214.2(h)( 4 )(iii)(A), it cannot be found that the proffered position qualifies as a specialty 
occupation. 
On appeal, the Petitioner asserts that it has submitted evidence that the Beneficiary "has attained the 
equivalent of a Bachelor's Degree in Computer Information Systems from an accredited institution 
of higher education in the United States. Therefore, it is to be duly noted that Petitioner has met the 
requirements for 'specialty occupation' under INA Section 214(i)(l)." 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. Thus, regardless of the Beneficiary's 
claimed qualifications, we cannot find that the proffered position qualifies as a specialty occupation 
for the reasons discussed above. Accordingly, the appeal will be dismissed. 
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Matter of N-, Inc. 
II. BENEFICIARY QUALIFICATIONS 
The Director also found that the Beneficiary would not be qualified to perform the duties of the 
proffered position. However, a beneficiary's credentials to perform a particular job are relevant only 
when the job is found to be a specialty occupation. As discussed in this decision, it cannot be found 
that the proffered position qualifies as a specialty occupation. Therefore, we need not and will not 
address the Beneficiary's qualifications further. 
III. PAYMENT OF REQUIRED WAGES 
Finally, the Director found that the Petitioner has not demonstrated that it will comply with the terms 
and conditions of the LCA. Again, however, since the proffered position does not qualify as a 
specialty occupation, we need not address this additional ground further, except to note that the 
clause making prohibited wage deductions from its Employment Agreement with the Beneficiary 
remains in its agreement. See section 101(a)(15)(H)(i)(b) ofthe Act; 20 C.P.R.§ 655.731(c). 
IV. CONCLUSION 
The Petitioner has not established that the proffered position, more likely than not, qualifies as a 
specialty occupation. In visa petition proceedings, it is the Petitioner's burden to establish eligibility 
for the immigration benefit sought. Section 291 ofthe Act, 8 U.S.C. § 1361; Matter ofOtiende, 26 
I&N Dec. 127, 128 (BIA 2013). Here, that burden has not been met. 
ORDER: The appeal is dismissed. 
Cite as Matter of N-, Inc., ID# 16485 (AAO May 31, 20 16) 
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