dismissed H-1B Case: Jewelry

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U.S. Citizenship 
and Immigration 
Services 
MATTER OF JKT-A-, INC. 
APPEAL OF VERMONT SERVICE CENTER DECISION 
Non-Precedent Decision of the 
Administrative Appeals Office 
DATE: NOV. 23,2016 
PETITION: FORM I-129, PETITION FOR A NONIMMIGRANT WORKER 
The Petitioner, a jewelry wholesaler and designer, seeks to extend the Beneficiary's temporary 
employment as a "business analyst" under the H-IB 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-IB 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, Vermont Service Center, denied the petition. The Director concluded that the 
_ Petitioner had not established that the proffered position is a specialty occupation. 
The matter is now before us on appeal. In its appeal, the Petitioner submits a brief and additional 
documentation and asserts that the Director erroneously concluded that it had not established that the 
proffered position is a specialty occupation. 
Upon de novo review, we will dismiss the appeal. 
I. LAW 
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.F .R. § 214.2(h)( 4 )(ii) largely restates this statutory definition, but adds a 
non-exhaustive list of fields of endeavor. In addition, the regulations provide that the proffered 
position must meet one of the following criteria to qualify as a specialty occupation: 
;------------------------------------------ ---- ---------- -
Matter of JKT-A-, Inc. 
(I) 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. 
8 C.F.R. § 214.2(h)(4)(iii)(A). U.S. Citizenship and Immigration Services (USCIS) has consistently 
interpreted 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 proposed 
position. See Royal Siam Corp. v. Chertoff, 484 F.3d 139, 147 (lstCir. 2007) (describing "a degree 
requirement in a specific specialty" as "one that relates directly to the duties and responsibilities of a 
particular position"); Defensor v. Meissner, 201 F.3d 384, 387 (5th Cir. 2000). 
II. PROFFERED POSITION 
In the H-1B petition, the Petitioner stated that it is a five-employee company and that the Beneficiary 
will serve as a full-time "business analyst." In response to the Director's request for evidence 
(RFE), the Petitioner listed the Beneficiary's duties as its business analyst and allocated the portion 
of time he will spend on each duty as follows: 
• Detailed Planning - analyze company needs; conduct business operations studies 
and perform inventory control analysis- 25% 
• Analyze [V]arious Business Models - updates different models for planning 
purposes and create rolling forecast; prepare inputs and participate in rolling 
forecast meetings with Sales Department- 25% 
• Designing Company Processes - prepare inputs for and participate in Pricing 
Committee and Sorting Review Meetings; provide analytical support for various 
ad hoc requests and projects - 30% 
• Business Analysis in IT - analysis and reporting of information regarding 
diamonds sales and marketing activities with focus on revenue forecasting for 
diamond producers; keep abreast of latest Information Technology (IT) to 
upgrade product analysis in terms of pricing and quality- 20% 
According to the Petitioner, "[p ]ossession of the Bachelor's degree in business administration is 
critical and key to performing the duties of the proffered position." 
2 
(b)(6)
Matter of JKT-A-, Inc. 
III. ANALYSIS 
Upon review of the record in its totality and for the reasons set out below, we determine that the 
Petitioner has not demonstrated that the proffered position qualifies as a specialty occupation.' 
Specifically, the record does not establish that the job duties require an educational background, or 
its equivalent, commensurate with a specialty occupation? 
On the labor condition application (LCA) submitted in support of the H-1 B petition, the Petitioner 
designated the proffered position under the occupational category "Management Analysts" 
corresponding to the Standard Occupational Classification code 13-1111.3 
A. First Criterion 
We tum first to the criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A)(l), which requires that a baccalaureate 
or higher degree in a specific specialty, or its equivalent, is normally the minimum requirement for 
entry into the particular position. To inform this inquiry, we recognize the U.S. Department of 
Labor's (DOL) Occupational Outlook Handbook (Handbook) as an authoritative source on the 
duties and educational requirements of the wide variety of occupations that it addresses.4 
1 The Petitioner submitted documentation to support the H-1 B petition, including evidence regarding the proffered 
position and its business operations. While we may not discuss every document submitted, we have reviewed and 
considered each one. 
2 Although some aspects of the regulatory criteria may overlap, we will address each of the criteria individually. 
3 The Petitioner classified the proffered position at a Level IV wage on the LCA, but indicated that the prevailing annual 
wage for the proffered position was $55,000. Upon review of the Foreign Labor Certification Data Center website, a 
$55,000 annual wage does not meet the prevailing wage of a Level I wage (the lowest of four assignable wage levels), let 
alone a Level IV wage. See http://tlcdatacenter.com/OesQuickResults.aspx?code= 13-
llll&area= &year=15&source=l (last visited Nov. 21, 2016). We will address the inconsistency and 
underpayment of the prevailing wage in the last section. We note here for the record that the "Prevailing Wage 
Determination Policy Guidance" issued by the DOL provides a description of the wage levels. A Level I wage rate is 
generally appropriate for positions for which the Petitioner expects the Beneficiary to have a basic understanding of the 
occupation. This wage rate indicates: (I) that the Beneficiary will be expected to perform routine tasks that require 
limited, if any, exercise of judgment ; (2) that he will be closely supervised and his work closely monitored and reviewed 
for accuracy; and (3) that he will receive specific instructions on required tasks .and expected results. U.S. Dep't of 
Labor , Emp't & Training Admin ., Prevailing Wage Determination Policy Guidance , Nonagric. Immigration Programs 
(rev. Nov. 2009), available at http://tlcdatacenter.com /download/NPWHC _Guidance_Revised_J 1_2009.pdf A 
prevailing wage determination starts with an entry level wage and progresses to a higher wage level after considering the 
experience, education , and skill requirements of the Petitioner's job opportunity. !d. 
4 All of our references are to the 2016-2017 edition of the Handbook, which may be accessed at the Internet site 
http_://www.bls .gov/ooh/. We do not, however , maintain that the Handbook is the exclusive source of relevant 
infon:nation. That is, the occupational category designated by the Petitioner is considered as an aspect in establishing the 
general tasks and responsibilities of a proffered position, and USC!S regularly reviews the Handbook on the duties and 
educational requirements of the wide variety of occupations that it addresses. To satisfy the first criterion, however, the 
burden of proof remains on the Petitioner to submit sufficient evidence to support a finding that its particular position 
would normally have a minimum , specialty degree requirement , or its equivalent , for entry. 
3 
(b)(6)
Matter of JKT-A- , Inc. 
The subchapter of the Handbook entitled "How to Become a Management Analyst" states, m 
relevant part: 
Most management analysts have at least a bachelor's degree. The Certified 
Management Consultant (CMC) designation may improve job prospects. 
Education 
A bachelor's degree is the typical entry-level requirement for management analysts. 
However, some employers prefer to hire candidates who have a master's degree in 
business administration (MBA). 
Few colleges and universities offer formal programs in management consulting. 
However, many fields of study provide a suitable education because of the range of 
areas that management analysts address. Common fields of study include business, 
management, economics, political science and government, accounting, finance, 
marketing, psychology, computer and information science, and English. 
Analysts also routinely attend conferences to stay up to date on current developments 
in their field. 
U.S. Dep't of Labor, Bureau of Labor Statistics, Occupational Outlook Handbook, 2016-17 ed., 
"Management Analysts," http://www.bls.gov/ooh/business-and-financial/management­
analysts.htm#tab-4 (last visited Nov. 21, 20 16). Here, the Handbook does not repm1 that bachelor's 
degrees held by those entering the occupation are limited to and must be in any specific specialty 
directly related to the occupation. Rather, the Handbook reports that a spectrum of degrees are 
acceptable to perform the duties of a management analyst. Accordingly, the Handbook does not 
support the assertion that at least a bachelor's degree in a spec(fic specialty is normally the minimum 
requirement for entry into this occupational category. We also note that a preference for a particular 
type of degree is not synonymous with a requirement for a degree in a specific discipline. 
When the Handbook does not support the proposition that a proffered position is one that meets the 
statutory and regulatory provisions of a specialty occupation, it is incumbent upon the Petitioner to 
provide persuasive evidence that the proffered position more likely than not satisfies this or one of 
the other three criteria, notwithstanding the absence of the Handbook's support on the issue. In such 
case, it is the Petitioner's responsibility to provide probative evidence (e.g., documentation from. 
other objective, authoritative sources) that supports a finding that the particular position in question 
qualifies as a speCialty occupation. Whenever more than one authoritative source exists, an 
adjudicator will consider and weigh all of the evidence presented to determine whether the particular 
position qualifies as a specialty occupation. 
In that regard, we have considered the printout from the website 
the Petitioner provides on appeal. The printout indicates that "[b ]usiness analysts are required to 
possess comprehensive business knowledge and skills, which can be obtained through a bachelor's 
4 
(b)(6)
Matter of JKT-A-, Inc. 
degree in business administration program with a specialization in management." Here, the 
Petitioner does not specify that its business/management analyst must have a business administration 
degree with a concentration in a specific specialty as a minimum to enter the position. Rather, the 
Petitioner indicates only that a general business administration degree is critical . and key to 
performing the duties of the proffered position. printout also 
notes that "[m]ost employers require business analysts to have a minimum of a bachelor's degree in 
business administration. "5 Here, the Petitioner does not demonstrate that the occupation of a 
business analyst requires ~ specific concentration in the general business administration field. On 
appeal 
and in support of this criterion, the Petitioner offers a conclusory statement regarding the 
Beneficiary's experience, asserts that his experience is equivalent to a U.S. four-year bachelor's 
degree in business administration, and claims that a bachelor's degree in business administration is 
relevant to the job duties of a business analyst. The Petitioner does not explain why such a degree is 
the minimum required to enter a business analyst occupation and significantly does not specify 
which courses, if any, in a general business administration degree are necessary to perform the duties 
of the occupation. We find that 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 administration, 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). 
Based on the above, the Petitioner has not satisfied the criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A)(l). 
B. Second Criterion 
The second criterion presents two, alternative prongs: "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[.]" 8 C.F.R. § 214.2(h)(4)(iii)(A)(2) (emphasis · added). The first prong 
concentrates on the common industry practice, while the alternative prong narrows its focus to the 
Petitioner's specific position. 
5 A' general degree in business or business administration alone is insufficient to qualify a beneficiary to perform the 
services of a specialty occupation, unless the academic courses pursued and knowledge gained is a realistic prerequisite 
to a particular occupation in the field. See Matter of Ling, 13 I&N Dec. 35 (Reg'! Comm'r 1968) (finding that 
"'Business administration' is a broad field, a field which contains various occupations and/or professions, all of which 
- are related to the world of business but each requiring a different academic preparation and experience peculiar to its 
needs"). Again , the Petitioner here does not specify that a degree in business administration with a specific 
concentration is necessary to perform the duties of a business analyst. Similarly, the 
while acknowledging that some employers prefer to hire candidates with a graduate degree or specialization, does not 
claim that a business administration degree with a specific concentration is normally the minimum requirement to enter 
the business analyst occupation. 
5 
Matter of JKT-A-, Inc. 
1. First Prong 
To satisfy this first prong of the second criterion, the Petitioner must establish that the "degree 
requirement" (i.e., a requirement of a bachelor's or higher degree in a specific specialty, or its 
equivalent) is common to the industry in parallel positions among similar organizations. 
In determining whether there is such a common degree requirement, factors often considered by 
USCIS include: whether the Handbook reports that the industry requires a degree; whether the 
industry's professional association has made a degree a minimum entry requirement; and whether 
letters or affidavits from firms or individuals in the industry attest that such firms "routinely employ 
and recruit only degreed individuals." See Shanti, Inc. v. Reno, 36 F. Supp. 2d 1151, 1165 (D. Minn. 
1999)(quoting Hird!Blaker Corp. v. Sava, 712 F. Supp. 1095, 1102 (S.D.N.Y. 1989)). 
Here and as already discussed, the Petitioner has not established that its proffered position is one for 
which the Handbook (or other independent, authoritative sources) reports an industry-wide 
requirement for at least a bachelor's degree in a specific specialty, or its equivalent. Thus, we 
incorporate by reference the previous discussion on the matter. Also, there are no submissions from 
the industry's professional association indicating that it has made a degree a minimum entry 
requirement. Furthermore, the Petitioner did not submit any letters or affidavits from similar firms 
or individuals in the Petitioner's industry attesting that such firms "routinely employ and recruit only 
de greed individuals." 
In support of its assertion that the degree requirement is common to the Petitioner's industry in 
parallel positions among similar organizations, the Petitioner submitted copies of advertisements 
from companies in the jewelry and apparel business as well as from advertisers in the governmental 
corrections and finance/banking industry. We have considered the Petitioner's assertion on appeal 
that the purpose of a business analyst position is the same no matter what industry employs a 
business analyst. However, to satisfy this particular pn;mg of this cri.terion, the regulation requires 
that the Petitioner establish that a degree requirement is common In similar organizations. 
Accordingly, the finance/banking and governmental corrections advertisers are not similar to the 
Petitioner's business. Additionally, the advertisements submitted from the retailers do not include 
sufficient information to ascertain their scope and size and thus similarity to the Petitioner's 
organization. Further, although the majority of advertisements require a bachelor's degree as a 
minimum requirement, only two advertisements reference fields of study and those two 
advertisements note that a broad range of study is acceptable including a general business 
administration degree. As the advertisers generally require only a bachelor's degree or a bachelor's 
degree in the general field of business administration as acceptable to perform the positions 
advertised, the advertisements do not establish that a bachelor's degree, or its equivalent, in a 
specific discipline is required. 
Upon review of all the advertisements submitted, the advt;rtisements are insufficient to demonstrate 
that the "degree requirement" (i.e., a requirement of a bachelor's or higher degree in a specific 
specialty, or its equivalent) is common to the Petitioner's industry in parallel positions among 
6 
Matter of JKT-A-, Inc. 
similar organizations. There is insufficient information within the advertisements to establish this 
prong of the criterion. 
Thus, the Petitioner has not satisfied the first alternative prong of8 C.F.R. § 214.2(h)(4)(iii)(A)(2). 
2. Second Prong 
',, 
We will next consider the second alternative prong of 8 C.F.R. § 214.2(h)(4)(iii)(A)(2), which is 
satisfied if the Petitioner shows that its particular position is so complex or unique that it can be 
performed only by an individual with at least a bachelor's degree in a specific specialty, or its 
equivalent. 
Upon review of the totality of the record, the Petitioner has not explained, or offered any evidence 
that the duties of the position proffered here are so complex and unique that a bachelor's degree in a 
specific specialty is required. In a company summary provided in response to the Director's RFE, 
the Petitioner stated that the Beneficiary would be "tasked with evaluating diamond acquisition 
prices, estimating selling prices low enough to attract clients, controlling costs of operations and 
strategically managing inventory to work in tandem with sales." These duties, as well as the duties 
describing the position more generally, do not show that a theoretical and practical application of a 
body of highly specialized knowledge such that a bachelor's or higher degree in a specific specialty, 
or its equivalent, is required to perform them. Moreover, the Petitioner does not offer its analysis on 
what detailed course of study leading to a specialty degree would be required to perform these or any 
of the duties described. Nor does the Petitioner explain and establish how such a curriculum is 
necessary to perform the duties it provided for the position. While a few related courses may be 
beneficial in performing certain duties of the position, the Petitioner has not demonstrated how an 
established curriculum of such courses leading to a baccalaureate or higher degree in a specific 
specialty, or its equivalent, is required to perform the duties of the proffered position. 
The evidence of record does not establish that this position is significantly different from other 
business/management analyst positions such that it refutes the Handbook's information to the effect 
that a general bachelor's degree is acceptable for this position. The record does not establish which 
of the duties, if any, of the proffered position would be so complex or unique as to be distinguishable 
from those of similar but non-degreed or non-specialty degreed employment. Rather, the Petitioner 
appears to rrely on the Beneficiary's work experience to support its claim that the proffered position 
is complex.
1 
However, the test to establish a position as a specialty occupation is not the education or 
experience of a proposed beneficiary, but whether the position itself requires at least a bachelor's 
degree in a specific specialty, or its equivalent. Accordingly, the Petitioner has not satisfied the 
second alternative prong of8 C.F.R. § 214.2(h)(4)(iii)(A)(2). 
C. Third Criterion 
The third criterion of 8 C.F.R. § 214.2(h)(4)(iii)(A) entails an employer demonstrating that it 
normally requires a bachelor's degree in a specific specialty, or its equivalent, for the position. In 
(b)(6)
Matter of JKT-A-, Inc. 
that regard, we reviewed the Petitioner's claim that it does not have self-imposed standards but that 
the position requires highly specialized knowledge and the attainment of a degree. As noted above, 
the Petitioner has not established why the duties described require a bachelor's degree in a specific 
specialty, or its equivalent. Further we reiterate that 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. Here, the Petitioner has not established that the duties of the 
position comprise the duties of a specialty occupation. The Petitioner also has not submitted 
evidence of individuals previously employed for this position and their academic credentials, if any. 
The Petitioner has not satisfied the criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A)(3). 
D. Fourth Criterion 
The fourth criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A) requires a petitioner to establish that the nature 
of the specific duties is so specialized and complex that the knowledge required to perform them is 
usually associated with the attainment of a baccalaureate or higher degree in a specific specialty, or 
its equivalent. 
The Petitioner does not offer probative evidence that the proffered position requires the performance 
of duties so specialized and complex that knowledge that is usually associated with the attainment of 
a baccalaureate orhigher"degree in a specific specialty, or its equivalent is required.6 That is, the 
Petitioner has not sufficiently developed relative specialization and complexity as an aspect of the 
proffered position. The Petitioner again references the printout from the 
website for the proposition that most employers require a bachelor's of business 
administration for business analyst positions. 7 However, to establish this criterion the Petitioner 
must discuss the duties of its particular position and establish why the duties it describes are so 
specialized and complex. The Petitioner has not offered any analysis of the duties described and has 
not further developed the duties in the context of its business operations. While we understand that 
the Petitioner expects the Beneficiary to have a business background to perform the duties it 
generally described, the Petitioner has not sufficiently explained how these duties require the 
theoretical and practical application of a body of highly specialized knowledge, and the attainment 
of a bachelor's or higher degree in the specific specialty (or its equivalent) as a minimum for entry 
6 The Petitioner has designated the proffered position as a full-time Level IV position on the submitted LCA, but 
indicates that it will pay the Beneficiary less than the required Level I wage. See 
http://f1cdatacenter.com/OesQuickResults.aspx?code= 13-1111 &area= &year= 15&source= 1 (last visited Nov. 21, 
20 16). Therefore, it does not appear that the position is one with specialized and complex duties as such a higher-level 
position would not only be classified as a Level Ill or Level IV position, but would include the corresponding payment 
of a significantly higher prevailing wage. 
7 We note that although a general-purpose bachelor's degree, such as a degree in business administration, 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. Chertojf, 484 F.3d 139, 147 
(I st Cir. 2007). 
8 
(b)(6)
Matter of JKT-A-, Inc. 
into the occupation in the United States. The Petitioner has not distinguished the duties of the 
proffered position as more specialized and complex than the duties of a business/management 
analyst position that does not require a bachelor's degree in a specific specialty. 
The record does not include sufficient probative evidence establishing that the duties of the proffered 
position require knowledge usually associated with the attainment of a baccalaureate or higher 
degree in a specific specialty, or its equivalent. The Petitioner has not satisfied the criterion at 
8 C.F.R. § 214.2(h)(4)(iii)(A)(4). 
The Petitioner has not established that it has satisfied any of the criteria at 8 C.F.R. 
§ 214.2(h)(4)(iii)(A) and, therefore, it cannot be fo.und that the proffered position qualifies as a 
specialty occupation. The appeal will be dismissed and the petition denied for this reason. 
IV. PREVAILING WAGE 
As the Petitioner did not demonstrate that the proffered position is a specialty occupation, we need 
not fully address other issues evident in the record. That said, we wish to identify an additional issue 
to inform the Petitioner that this matter should be addressed in any future proceedings. 8 
The petition cannot be approved because the record of proceedings lacks probative evidence 
demonstrating that the Petitioner will offer a wage equal to or greater than that required by law. 
Section 212(n)(l)(A) of the Act, 8 U.S.C. § 1182(n)(l)(A), states that the Petitioner must offer 
wages that are at least "the actual wage level paid by the employer to all other individuals with 
similar experience and qualifications for the specific employment in question" or "the prevailing 
wage level for the occupational classification in the area of employment, whichever is greater." 
Here, the Petitioner stated in the Form I-129 petition that it would pay the Beneficiary $55,000 per 
year for full-time work as its business analyst. The Petitioner classified the proffered position under 
the occupational category "Management Analysts" corresponding to the Standard Occupational 
Classification code 13-1111, at a Level IV wage. The Petitioner specified the wage rate for the 
full-time position in the New York county area as $55,000 annually. 
Upon review of the Foreign Labor Certification Data Center website, the prevailing wage for a Level 
IV management analyst'in' was $132,558 annually when the LCA was 
certified. The prevailing wage for a Level I management analyst for the same time period in the 
same county was $57,678. See http://flcdatacenter.com/OesQuickResults.aspx?code=13-
1111&area= &year=15&source=l (last visited Nov. 21, 2016). Accordingly, the Petitioner has 
not attested that it will pay the prevailing wage in this area for even the lowest of the four assignable 
wage levels. Therefore, as the Petitioner has not offered a wage that is equal to or greater than the 
8 In reviewing a matter de novo, we may identify additional issues not addressed below in the Director's decision. See 
Spencer Enterprises, Inc. v. United States, 229 F. Supp. 2d 1025, 1043 (E.D. Cal. 2001), affd, 345 F.3d 683 (9th Cir. 
2003) ("The AAO may deny an application or petition on a ground not identified by the Service Center."). 
9 
Matter of JKT-A-, Inc. 
prevailing wage, and has not provided any other evidence establishing the required wage the petition 
cannot be approved for this additional reason. 
V. CONCLUSION 
The burden is on the Petitioner to show eligibility for the immigration benefit sought. Section 291 of 
the Act, 8 U.S.C. § 1361; Matter ofOtiende, 26 I&N Dec. 127, 128 (BIA 2013). Here, that burden 
ha$ not been met. 
ORDER: The appeal is dismissed. 
Cite as Matter of JKT-A-, Inc., ID# 12662 (AAO Nov. 23, 2016) 
10