dismissed H-1B Case: Software Development

MATTER OF H-G-ITS- CORP. 
APPEAL OF VERMONT SERVICE CENTER DECISION 
Non-Precedent Decision of the 
Administrative Appeals Office 
DATE: JAN. 30, 2017 
PETITION: FORMI-129, PETITION FOR A NONIMMIGRANT WORKER 
The Petitioner, a software development, outsourcing, and consulting company, seeks to temporarily 
employ the Beneficiary as a "project manager" under the H-1 B nonimmigrant classification for 
specialty occupations. See Immigration and Nationality Act (the Act) section 101(a)(l5)(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, Vermont Service Center, denied the petition. The Director concluded that the 
Petitioner had not demonstrated that the proffered position qualifies as a specialty occupation 
position. 
The matter is now before us on appeal. In its appeal, the Petitioner submits additional evidence and 
asserts that the evidence is sufficient to satisfy all evidentiary requirements. 
Upon de novo review, we will dismiss the appeal. 
I. 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.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 H-G-ITS- Corp. 
(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. 
8 C.P.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.P.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. Cherto_ff, 484 P.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"); Defensor v. Meissner, 201 P.3d 384, 387 (5th Cir. 2000). 
We note that, as recognized by the court in Defensor, 201 P.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, 201 P.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 
bCJ.sis 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. 
II. PROFFERED POSITION 
In the H-1B petition, the Petitioner stated that the Beneficiary will serve as a "project manager." In a 
letter provided with the petition, as well as in Annexure "A" of the employment agreement, the 
Petitioner provided the following duty description for the position: 
• Use various project management tools and software applications to proactively 
track, monitor and control project deliverables. Manages the triple constraint (time 
vs. scope vs. cost). 
• Prioritize and delegate project tasks, providing timely direction and support to 
project team on a day to day basis. Proactively manage project risks, including the 
identification of mitigation strategies[.] 
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Matter of H-G-ITS- Corp. 
• Performs project reporting & communications (Including weekly status updates 
and/or Exec Steering Committee meetings). Challenges performance gaps of 
project team members and provides coaching/mentoring support. 
• Facilitate meeting and design workshops, testing activities, and post go live support 
keeping a keen eye on quality. 
• Ability to lead a team of project personnel consisting of functional 
analysts/technical analysts (staff and/or contracted independent contractors), and 
business personnel to the successful implementation of the documented project 
scope. 
• Create a detailed work plan which identifies and sequences the activities needed to 
successfully complete a project. 
• Manage the execution [of] the project according to the project plan. Recruit, 
interview and select staff and/or volunteers with appropriate skills for the project 
activities. 
• Ensure that all project personnel receive an appropriate orientation to the 
organization and governance of the project. 
• Control assigned projects, including weekly status meetings, and monitoring of 
project spending. Communicate status via a weekly status report. 
• Coordinate or participate in all phases of the project lifecycle, including planning, 
design, development, testing, implementation, documentation, training, and closure. 
• Ensure that the project achieves the expected results within time and on budget. 
Ensure effecting ongoing communication throughout the project. Meet with key 
managers to coordinate meetings, assignments and deadlines. 
• Communicate changes to appropriate parties. Identify issues and resolve or escalate 
them as appropriate. Gather, organize, analyze and, report information in support 
of moderately complex projects to improve profitability, reduce costs, streamline 
operations, or enhance customer service., 
• Represent business unit, department, or functional area on cross-functional project 
teams. Track progress towards achievement of project goals. 
• Facilitate complex team meetings involving business and technical resources. 
Demonstrate credibility as an IT partner to ensure business and technology 
decisions are reached to support business goals and objectives. 
• Specific functional/technical subject matter expertise in Marketing, Sales, and 
Customer Relationship management. Proven experience managing complex 
projects from conception to completion with limited guidance. Experience across 
the entire delivery lifecycle (SDLC). 
• Demonstrated ability to command the attention and respect of senior-level leade.rs 
and confidently make presentations to large and executive audiences. 
• Knowledge of concepts, techniques, and tools relating to coordinating and tracking 
projects. Knowledge of standards, practices and techniques of project management. 
• Configure/apply software systems to meet defined project objectives, in accordance 
with the project scope document and/or functional specifications. Design system 
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Matter of H-G-ITS- Corp. 
enhancements (workflows, reports, interfaces, converswns, enhancements, and . 
forms). 
• Perform data analysis, mapping, and transformation, both as a part of system 
conversion/cut-over activities and routine operation of software systems. 
• Design the system security concept, including adherence to the organization's 
internal controls framework . 
• Perform unit and integration testing of all new developments and changes to 
software systems[.] 
• Performs a project 
leader role, providing planning, direction, coordination and daily 
supervision to the project team to ensure the objectives and tasks of the project are 
accomplished on time and within budget. 
• Consults with the business departments and process owners in defining business 
requirements and ensuring the solution meets those requirements. 
• Ensures that the project team follows proper life cycle development techniques, 
PMO processes and procedures and company and internal policies and practices. 
Prepares projects for the ITS Steering Committee. 
• Work closely with Business teams and SAP functional and technical experts to 
define project scope and all required deliverables, activities, activity sequence, 
Work Breakdown Structure (WBS) and work estimates to create a framework for 
the project schedule. 
The Petitioner also stated that the proffered position requires at least a bachelor's degree in computer 
science, information science , or the equivalent. 
The Petitioner submitted a memorandum which provided an overview of the claimed IT project upon 
which the Beneficiary would work. Specifically, the Petitioner stated that it has been contracted to 
perform migration services on behalf of , pursuant to its contract 
with The Petitioner submitted a copy of its service agreement and statement 
of work (SOW) with . The service agreement, executed in February of 2015, indicates 
that the timeline for this project is 18 months. The record does not contain a copy of the contract 
executed between and the Petitioner. 
III. ANALYSIS 
Upon review of the record in its totality and for the reasons set out below, we determine t~at the 
Petitioner has not demonstrated that the proffered position qualifies as a specialty occupation. 
Specifically, we find that the record of proceedings lacks sufficient documentation to substantiate the 
claim that the Petitioner has H-lB caliber work for the Beneficiary for the period of employment 
requested in the petition. 1 
1 The "preponderance of the evidence" standard requires that the evidence demonstrate that the Petitioner's claim is 
"probably true," where the determination of "truth" is made based on the factual circumstances of each individual 
case. Matter ofChawath e, 25 I&N Dec. 369, 376 (AAO 2010) (citing Matter of E-M-, 20 l&N Dec. 77, 79-80 (Comm ' r 
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(b)(6)
Matter of H-G-ITS- Corp. 
For example, the Petitioner claims that the Beneficiary will perform migration services for 
which appears to be the end client and receiver of the Petitioner's services in this matter. However, 
despite the submission of various documents, including the above-reference service agreement and 
SOW with , no contractual documentation establishing the 
claimed relationship between 
and , or documentation definitively establishing the role of the Petitioner and its 
personnel within this relationship, has been submitted. While the Petitioner's memorandum outlines 
the duties the Beneficiary will perform as project manager on this project, the document is an 
internally generated memorandum and is insufficient to substantiate the contractual terms and 
specifics of the Beneficiary's claimed assignment. 
The service agreement further indicates that the migration project (Wave 1) for which the 
Beneficiary's services are required has a time line of 18 months, beginning on March 1, 2015. It 
appears that the project will be completed by August of 2016. However, the 'Petitioner has requested 
approval for the Beneficiary for a 2-year period, from June 2016 to June 2018. Based on these 
claims, there is no project or other defined assignment for the,Beneficiary for the majority of the 
requested validity period. 
We note the Petitioner's assertions on appeal that Waves 2 and 3 of the migration project will carry 
the project through the requested validity period ending in June 2018. We disagree. The service 
agreement clearly states: "Upon completion of Wave 1 of the PROJECT this agreement will 
terminate by operation of law. A separate Service Agreement will be done between the parties for 
Wave 2 and Wave 3." At the time of filing, the only valid agreement contained in the record, therefore, 
was for services between March 2015 and August 2016. 
In addition, the record is devoid of any agreement between , the ultimate end-client, and either 
or the Petitioner. Therefore, the underlying service agreement between and the 
Petitioner is insufficient to demonstrate that H -1 B caliber work exists for the Beneficiary throughout the 
requested validity period. There is no documentation regarding the expectations of for the 
Beneficiary and his co-workers, nor is there evidence as to who ultimately delegates and controls the 
Beneficiary's work. Although we note the Petitioner's assertion in response to the Director's request 
for evidence (RFE) that there is no relationship between the Petitioner and , the fact that the 
Petitioner has been contracted to perform migration services for through an agreement with 
negates this statement. 
Finally, it is .noted in the Petitioner's memorandum that all employees of the Petitioner assigned to the 
project will report to the Beneficiary. However, the record is devoid of a similar statement establishing 
1989)). In evaluating the evidence, the truth is to be determined not by the quantity of evidence alone but by its quality. 
ld Thus, in adjudicating the petition pursuant to the preponderance of the evidence standard, we must examine each 
piece of evidence for relevance, probative value, and credibility, both individually and within the context of the totality 
of the evidence, to determine whether the fact to be proven is probably true. 
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(b)(6)
Matter of H-G-ITS- Corp. 
to whom the Beneficiary will report, and whether his work will be delegated and controlled by the 
Petitioner, or 
Without ~ purchase order or contract that outlines the terms and conditions of the Beneficiary's 
employment and information regarding specific projects to which the Beneficiary would be assigned 
that covers the duration of the period of employment requested, we are not able to ascertain what the 
Beneficiary would do, where the Beneficiary would work, or how this would impact circumstances of 
his relationship with the Petitioner. Further, there is no evidence of any binding obligation on the part 
of the end-client to provide any work for the Beneficiary to perform. A petition must be filed for non­
speculative work for the Beneficiary, for the entire period requested, that existed as of the time of the 
petition's filing. The Petitioner must establish eligibility at the time of filing the nonimmigrant visa 
petition. 8 C.F .R. § 103 .2(b )(1 ). A visa petition may not be approved based on speculation of future 
eligibility or after the Petitioner or Beneficiary becomes eligible under a new set of facts. See Matter 
of Michelin Tire Corp., 17 I&N Dec. 248 (Reg'l Comm 'r 1978).2 While the agreement between the 
Petitioner and may in fact encompass a legitimate project, the 
lack of additional 
documentation outlining the exact nature of the Beneficiary's role in this project renders it 
impossible to ascertain the true nature of his proposed employment. This lack of documentation, 
coupled with the absence of additional evidence demonstrating that H -1 B caliber assignments exist 
through the requested validity period ending in June 2018, prohibit approval ofthe instant petition. 
The record lacks evidence sufficiently informative to demonstrate that the proffered position 
qualifies as a specialty occupation under 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 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 
2 The agency made clear long ago that speculative employment is not permitted in the H-1 B program. For example, a 
1998 proposed rule documented this position as follows: 
Historically, the Service has not granted H-1 B classification on the basis of speculative, or 
undetermined, prospective employment. The H-1 B classification is not intended as a vehicle for an 
alien to engage in a job search within the United States, or for employers to bring in temporary foreign 
workers to meet possible workforce needs arisin.g from potential business expansions or the 
expectation of potential new customers or contracts. To determine whether an alien is properly 
classifiable as an H-1 B nonimmigrant under the statute, the Service must first examine the duties of the 
position to be occupied to ascertain whether the duties of the position require the attainment of a 
specific bachelor's degree. See section 214(i) of the Immigration and Nationality Act (the "Act"). The 
Service must then determine whether the alien has the appropriate degree for the occupation. In the 
case of speculative employment, the Service is unable to perform either part of this two-prong analysis 
and, therefore, is unable to adjudicate properly a request for H-1 B classification. Moreover, there is no 
assurance that the alien will engage in a specialty occupation upon arrival in this country. 
Petitioning Requirements for the H ·Nonimmigrant Classification, 63 Fed. Reg. 30,419, 30,419-20 (proposed June 4, 
1998) (to be codified at 8 C.F.R. pt. 214). While a petitioner is certainly permitted to change its intent with regard to 
non-speculative employment, e.g., a change in duties or job location, it must nonetheless document such a material 
change in intent through an amended or new petition in accordance with 8 C.F.R. § 214.2(h)(2)(i)(E). 
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Matter of H-G-ITS- Corp. 
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. Thus, the Petitione~ has not satisfied any of the criteria under the 
applicable provisions at 8 C.F.R. § 214.2(h)(4)(iii)(A). 
Nevertheless, we will continue our evaluation and analysis of the evidence provided by the 
Petitioner.3 Upon review, we find that the record does not establish that the job duties require an 
educational background, or its equivalent, commensurate with a specialty occupation.4 
A. First Criterion 
We turn 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.5 
On the labor condition application (LCA)6 submitted in support of the H-lB petition, the Petitioner 
designated the proffered position under the occupational category "Computer Occupations, All 
Other" corresponding to the Standard Occupational Classification code 15-1199. However, the 
Handbook does not provide a detailed narrative account nor does it provide summary data. for this 
occupational category. More specifically, the Handbook does not provide the typical duties and 
responsibilities for positions located within the "Computer Occupations, All Other" occupational 
category. It also does not provide any information regarding the academic and/or professional 
requirements for these positions. Thus, the Handbook does not support the claim that the 
occupational category here is one for which normally the minimum requirement for entry is a 
baccalaureate degree (or higher) in a specific specialty, or its equivalent. 
3 
Although some aspects of the regulatory criteria may overlap, we will address each of the criteria individually. 
4 
The Petitioner submitted documentation to support the H-1 8 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. 
5 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 
information. 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 IS 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. 
6 The Petitioner is required to submit a certified LCA to USC IS to demonstrate that it will pay an H-1 8 worker the 
higher of either the prevailing wage for the occupational classification in the "area of employment" or the actual wage 
paid by the employer to other employees with similar experience and qualifications who are performing the. same 
services. See Matter ofSimeio Solutions, LLC, 26 I&N Dec. 542, 545-546 (AAO 20 15). 
Matter of H-G-ITS- Corp. 
The evidence submitted does not demonstrate that a baccalaureate or higher degree in a specific 
specialty, or its equivalent, is normally the minimum requirement for entry into the proffered 
position. Further, the Petitioner has not provided documentation from other probative sources to 
substantiate its assertion regarding the minimum requirement for entry into this particular position. 
Thus, the Petitioner has not satisfied the criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A)(1). 
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 
casts its gaze upon the common industry practice, while the alternative prong narrows its focus to the 
Petitioner's specific position. 
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) 
(quotingHird/BlakerCorp. v. Sava, 712F. 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 source) 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 degreed 
individuals." Nor is there any other evidence for our consideration under this prong. 
Thus, the evidence of record does not establish that a requirement of a bachelor's or higher degree in 
a specific specialty, or its equivalent, is common to parallel positions with organizations that are in 
the Petitioner's industry and otherwise similar to the Petitioner. The Petitioner has not, therefore, 
satisfied the criterion ofthe first alternative prong of8 C.F.R. § 214.2(h)(4)(iii)(A)(2). 
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Matter of H-G-ITS- Corp. 
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. 
A review of the record of proceedings finds that the Petitioner has not credibly demonstrated that the 
duties the Beneficiary will be responsible for or perform on a day-to-day basis constitute a position 
so complex or unique that it can only be performed by a person with at least a bachelor's degree in a 
specific specialty, or its equivalent. The evidence of record does not establish why a few related 
courses or industry experience alone would be insufficient preparation for the proffered 
position. While related courses may be beneficial, or even required, 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 description of the duties does not specifically 
identify any tasks that are so complex or unique that only a specifically degreed individual could 
perform them. by persons without at least a bachelor's degree in a specific specialty, or its 
equivalent. Therefore, the Petitioner has satisfied the second alternative prong of 8 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. 
The Petitioner stated in response to the RFE that it previously employed two individuals in the 
position of project manager. In support of this assertion it submitted copies of their foreign 
academic credentials and credentials evaluations. However, this assertion is not supported by 
documentary evidence, such as an organizational chart verifying the position of these individuals in 
the Petitioner's organizational hierarchy, or copies of pay stubs, wage and tax statements (Forms 
W-2), or other such documentation to establish that these individuals were actually employed by the 
Petitioner in the capacity claimed. A petitioner's unsupp~rted statements are of very limited weight 
and normally will be insufficient to carry its burden of proof. See Matter of So.ffici, 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)); see also Matter of Chawathe, 25 I&N Dec. 369, 376 (AAO 2010). The Petitioner must 
support its assertions with relevant, probative, and credible evidence. See Matter of Chawathe, 25 
I&N Dec. at 376. 
In any event, the Petitioner did not provide any evidence pertinent to the qualifications of any of its 
other employees, and has not, therefore, provided sufficient evidence to satisfy the criterion at 
8 C.F.R. § 214.2(h)(4)(iii)(A)(3). 
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Matter of H-G-ITS- Corp. 
D. Fourth Criterion 
The fourth criterion at 8 C.P.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. 
In the instant case, relative specialization and complexity have not been sufficiently developed by 
the Petitioner as an aspect of the proffered position. The record does not demonstrate that the duties 
of the proffered position, such as managing client projects, require a minimum of a bachelor's 
degree in a specific specialty or its equivalent. The Petitioner has not, therefore, satisfied the 
criterion at 8 C.F.R. § 214.2(h)(4)(iii)(A). 
Because the Petitioner has not satisfied one of the criteria at 8 C.P.R.§ 214.2(h)(4)(iii)(A), it has not 
demonstrated that the proffered position qualifies as a specialty occupation. 
IV. 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. Here, that burden has not been met. 
ORDER: The appeal is dismissed. 
Cite as Matter of H-G-ITS- Corp., ID# 101817 (AAO Jan. 30, 2017) 
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