dismissed L-1A Case: Human Resources Consulting

U.S. Citizenship 
and Immigration 
Services 
MATTER OF 747G- LLC 
APPEAL OF VERMONT SERVICE CENTER DECISION 
Non-Precedent Decision of the 
Administrative Appeals Office 
DATE: OCT. 21, 2016 
PETITION: FORM I-129, PETITION FOR A NONIMMIGRANT WORKER 
The Petitioner, a human resources consulting firm, seeks to extend the Beneficiary's temporary 
employment as its managing director under the L-1 A nonimmigrant classification for intracompany 
transferees. See Immigration and Nationality Act (the Act) section 101(a)(l5)(L), 8 U.S.C. 
§ 1101(a)(15)(L). The L-1A classification allows a corporation or other legal entity (including its 
affiliate or subsidiary) to transfer a qualifying foreign employee to the United States to work 
temporarily in a managerial or executive capacity. 
The Director, Vermont Service Center, denied the petitiOn. The Director concluded that the 
evidence of record did not establish that the Beneficiary would be employed in a managerial or 
executive capacity under the extended petition. 
The matter is now before us on appeal. In its appeal, the Petitioner submits additional evidence and 
asserts that the evidence of record establishes that the Beneficiary would perform primarily 
executive duties. The Petitioner contends that the Director placed undue emphasis on the 
Petitioner's staffing levels and overlooked its use of contractors. 
Upon de novo review, we will dismiss the appeal. 
I. LEGAL FRAMEWORK 
To establish eligibility for the L-1 nonimmigrant visa classification, a qualifying organization must 
have employed the Beneficiary in a managerial or executive capacity, or in a specialized knowledge 
capacity, for one continuous year within three years preceding the Beneficiary's application for 
admission into the United States. Section 101(a)(15)(L) of the Act. In addition, the Beneficiary 
must seek to enter the United States temporarily to continue rendering his or her services to the same 
employer or a subsidiary or affiliate thereof in a managerial, executive, or specialized knowledge 
capacity. !d. 
The regulation at 8 C.F.R. § 214.2(1)(3) states that an individual petition filed on Form I-129, 
Petition for a Nonimmigrant Worker, shall be accompanied by: 
Matter of747G- LLC 
(i) Evidence that the petitioner and the organization which employed ol will 
employ the alien are qualifying organizations as defined in paragraph 
(l)(l)(ii)(G) ofthis section. 
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(ii) Evidence that the alien will be employed in an executive, managerial, or 
specialized knowledge capacity, including a detailed description of the 
services to be performed. 
(iii) Evidence that the alien has at least one continuous year of full-time 
employment abroad with a qualifying organization within the three years 
preceding the filing of the petition. 
(iv) Evidence that the alien's prior year of employment abroad was in a position 
that was managerial, executive or involved specialized knowledge and that the 
alien's prior education, training, and employment qualifies him/her to perform 
the intended services in the United States; however, the work in the United 
States need not be the same work which the alien performed abroad. 
The regulation at 8 C.F.R. § 214.2(1)(14)(ii) also provides that a visa petition, which involved the 
opening of a new office, may be extended by filing a new Form 1-129, accompanied by the 
following: 
(A) Evidence that the United States and foreign entitles are still qualifying 
organizations as defined in paragraph (1)(1 )(ii)(G) of this section; 
(B) Evidence that the United States entity has been doing business as defined in 
paragraph (1)(1 )(ii)(H) of this section for the previous year; 
(C) A statement of the duties performed by the beneficiary for the previous year 
and the duties the beneficiary will perform under the extended petition; 
(D) A statement describing the staffing of the new operation, including the 
number of employees and types of positions held accompanied by evidence of 
wages paid to employees when the beneficiary will be employed in a 
managerial or executive capacity; and 
(E) Evidence ofthe financial status ofthe United States operation. 
II. EMPLOYMENT IN A MANAGERIAL OR EXECUTIVE CAPACITY 
The Director denied the petition based on a finding that the Petitioner did not establish that the 
Beneficiary will be employed in a managerial or executive capacity under the extended petition. 
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Matter of747G- LLC 
A. Law 
Section 101(a)(44)(A) of the Act, 8 U.S.C. § 1101(a)(44)(A), defines the term "managerial capacity" 
as "an assignment within an organization in which the employee primarily": 
(i) manages the organization, or a department, subdivision, function, or 
component of the organization; 
(ii) supervises and controls the work of other supervisory, professional, or 
managerial employees, or manages an essential function within the 
organization, or a department or subdivision of the organization; 
(iii) if another employee or other employees are directly supervised, has the 
authority to hire and fire or recommend those as well as other personnel 
actions (such as promotion and leave authorization), or if no other employee is 
directly supervised, functions at a senior level within the organizational 
hierarchy or with respect to the function managed; and 
(iv) exercises discretion over the day-to-day operations of the activity or function 
for which the employee has authority. 
Further, "[a] first-line supervisor is not considered to be acting in a managerial capacity merely by 
virtue ofthe supervisor's supervisory duties unless the employees supervised are professional." !d. 
Section 101(a)(44)(B) of the Act, 8 U.S.C. § 1101(a)(44)(B), defines the term "executive capacity" 
as "an assignment within an organization in which the employee primarily": 
(i) directs the management of the organization or a major component or function 
of the organization; 
(ii) establishes the goals and policies of the organization, component, or function; 
(iii) exercises wide latitude in discretionary decision-making; and 
(iv) receives only general supervision or direction from higher-level executives, 
the board of directors, or stockholders of the organization. 
If staffing levels are used as a factor in determining whether an individual is acting in a managerial 
or executive capacity, U.S. Citizenship and Immigration Services (USCIS) must take into account 
the reasonable needs of the organization, in light of the overall purpose and stage of development of 
the organization. See section 1 01 (a)( 44 )(C) of the Act. 
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Matter of747G- LLC 
B. Analysis 
Upon review of the petition and the evidence of record, including materials submitted in support of 
the appeal, we conclude that the Petitioner has not established that the Beneficiary will be employed 
in a managerial or executive capacity under the extended petition. 
When examining the managerial or executive capacity of the Beneficiary, we will look first to the 
Petitioner's description of the job duties. See 8 C.F.R. § 214.2(1)(3)(ii). The Petitioner's description 
of the job duties must clearly describe the duties to be performed by the Beneficiary and indicate 
whether such duties are in a managerial or executive capacity. !d. 
In a letter submitted at the time of filing, the Petitioner described the Beneficiary's position as a 
"high-level executive position" involving top-level decision-making authority and responsibility for 
the overall direction of the company, and provided the following duties: 
• Establish the Company's plans and goals in the US; 
• Execute the company's business strategies; 
• Promote the Company's image and reputation; 
• Greatly increase awareness of the Company among the corporate business 
community; 
• Establish a sales and growth plan, and implement that plan to achieve revenue 
targets; 
• Recruit the necessary staff; and 
• Lead an effective operating model for [the Petitioner]. 
In a request for evidence (RFE), the Director advised the Petitioner tha:t this description was 
insufficient to establish the Beneficiary's eligibility and requested, among other items, a more 
detailed statement of what the Beneficiary would actually be doing on a daily basis. 
In response, the Petitioner emphasized that the position is "clearly executive" and provided the 
following breakdown of the Beneficiary's duties: 
• Establishing the company's presence in the U.S. by founding partnerships with 
clients ... (20%) ... ; 
• Promoting the company's image and reputation by active participation in 
exhibitions and local chapters events ... (15%) ... ; 
• Greatly increase awareness of the company by building strategic alliances with 
the corporation business community ... (5%) ... ; 
• Establishing a sales and growth plan and executing that plan to achieve revenue 
targets (10%); 
• Recruiting the necessary staff and setting in motion an effective operating model 
for [the Petitioner] (10%); 
• Selecting, developing, coaching and evaluating personnel ... ; 
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Matter of747G- LLC 
• Managing people who lead projects supporting the company-client 
relationships and ensuring customer satisfaction; 
• Hiring, terminating and training staff; 
• Building and maintaining an effective management team; 
• Overseeing the company's financial functions including financial plans and 
policies, accounting practices and procedures, and the organization's relationship 
with the financial community ... (1 0%) ... ; 
• Oversees the execution and completion of customer projects, including . . . 
monitoring project completion from initiation through delivery to meet revenue 
and cost projections ... (1 0%) ... ; 
• Analyzing budget reports, planning, and coordination of activities between clients 
and company personnel ... (5%); ... ; 
• Sustaining, growing and adding new programs and service ... (5%) ... ; 
• Meeting potential clients by growing, maintaining and identifying potential clients 
and decision makers within the client organization ... (5%); 
• Maintaining a dialogue between shareholders and the board via financial 
reporting; and assuming full accountability for the board for all company 
operations. (5%). 
The definitions of managerial and executive capacity each have two parts. First, the Petitioner must 
show that the Beneficiary will perform certain high-level responsibilities. Champion World, Inc. v. 
INS, 940 F.2d 1533 (9th Cir. 1991) (unpublished table decision). Second, the Petitioner must prove 
that the Beneficiary will be primarily engaged in managerial or executive duties, as opposed to 
ordinary operational activities alongside the Petitioner's other employees. See Family Inc. v. USCIS, 
469 F.3d 1313, 1316 (9th Cir. 2006); Champion World, 940 F.2d 1533. 
Here, the Petitioner has consistently stated that the Beneficiary's role will be in an executive 
capacity and will include high-level responsibilities and authority to direct the organization; 
however, it has not provided sufficient detail to establish that the actual duties the Beneficiary will 
perform on a day-to-day basis will be primarily executive in nature. The Petitioner's initial 
description of his duties largely paraphrased the statutory definition of executive capacity and did 
not provide any insight into the nature of the Beneficiary's daily tasks. Conclusory assertions 
regarding the beneficiary's employment capacity are not sufficient. Merely repeating the language 
of the statute or regulations does not satisfy the petitioner's burden of proof. See Fedin Bros. Co., 
Ltd. v. Sava, 724 F. Supp. 1103, 1108 (E.D.N.Y. 1989), aff'd, 905 F. 2d 41 (2d. Cir. 1990); Avyr 
Associates, Inc. v. Meissner, 1997 WL 188942 at *5 (S.D.N.Y.). 
While the Petitioner submitted a lengthier description in response to the RFE, it did not further 
explain the duties provided at the time of filing. Rather, the Petitioner stated that the seven duties in 
the initial description would require only 60% of his time and then added six additional 
responsibilities which would make up the remainder of his time. The Petitioner did not explain why 
these new duties were not included at the time of filing. The purpose of the RFE is to elicit further 
information that clarifies whether eligibility for the benefit sought has been established. 8 C.F.R. § 
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Matter of747G- LLC 
103.2(b)(8). The information provided by the Petitioner in its response to the Director's RFE did not 
clarify or provide more specificity to the original duties of the position, but rather added new duties 
to the job description. 
Further, to the extent that the Petitioner described the Beneficiary's duties, those duties indicate that 
he will be directly responsible for the company's marketing, promotion and business development 
activities. Specifically, the Beneficiary is responsible for securing clients, promoting the company at 
exhibitions and workshops, executing a "sales and growth plan," building alliances within the 
business community, and identifying and meeting potential clients. These duties constitute 55 
percent of the Beneficiary's time and have not been explained in sufficient detail to be characterized 
as clearly managerial or executive in nature, particularly in light of the lack of evidence that the 
Beneficiary has subordinate personnel to assist him with these business development functions, 
which will be discussed below. In response to the RfE, the Petitioner identified some specific 
clients, exhibitions, and business organizations as the Beneficiary's contacts, but did not elaborate on 
his actual duties. 
The Petitioner asserts that the Beneficiary will allocate an additional 15% of his time to overseeing 
financial functions including directing the controller, accounting, treasury, and tax functions. While 
'Ye do not doubt the Beneficiary's overall responsibility for the company's profits and losses, the 
Petitioner has not provided evidence of who is actually performing the various financial activities the 
Beneficiary is claimed to oversee. Also, the Petitioner allocates 10% of the Beneficiary's time to 
overseeing customer projects from initiation through delivery, but does not explain what tasks he 
performs or explained how projects are carried out, other than noting that projects are handled "via 
collaboration with industry experts and clients." Again, the Petitioner identified specific projects, 
but did not explain who among the Petitioner's employees or contractors would actually provide 
services to clients, information that would support its claim that the Beneficiary spends only a small 
time on client project activities. 
Reciting a beneficiary's vague job responsibilities or. broadly-cast business objectives is not 
sufficient; the regulations require a detailed description of the beneficiary's daily job duties. The 
Petitioner has not provided sufficient detail or explanation of the Beneficiary's activities in the 
course of his daily routine. The actual duties themselves will reveal the true nature of the 
employment. Fedin Bros. Co., Ltd. v. Sava, 724 F. Supp. 1103, 1108 (E.D.N.Y. 1989), aff'd, 905 
F.2d 41 (2d. Cir. 1990). Overall, the position descriptions submitted are inconsistent, vague, and 
include potentially non-qualifying duties, making these descriptions alone insufficient to support the 
Petitioner's claim that the Beneficiary performs primarily executive duties. 
Beyond the required description of the job duties, USCIS reviews the totality of the record when 
examining the claimed managerial or executive capacity of a beneficiary, including the company's 
organizational structure, the duties of a beneficiary's subordinate employees, the presence of other 
employees to relieve a beneficiary from performing operational duties, the nature· of the business, 
and any other factors that will contribute to understanding a beneficiary's actual duties and role in a 
business. 
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(b)(6)
Matter of747G- LLC 
The Petitioner, described in the record as a human resources consulting firm, provided evidence that 
it had hired two employees (a client service manager and client service assistant) during its initial 
year of operations and had opened a branch office in California. At the time of filing, in March 
2015, the Petitioner stated that it expected to hire a sales manager and up to four sales people by 
2018, and, within five years, a marketing employee and an engineering employee. Ip response to the 
RFE, the Petitioner stated that both subordinate employees had left the company in August 2015. 
The Petitioner provided evidence that it had hired a business development assistant on November 20, 
2015. The Petitioner did not state that it was attempting to fill the client service manager or client 
service assistant positions that had been vacated, but it did identify four' contractors who "provide 
shorter-term project-based work and trainings" for clients. 
The Petitioner's RFE response also included an undated organizational chart which appears to depict 
the strvcture of the company as of January 2016. The chart depicts the Beneficiary supervising three 
consultants (including two of the claimed contractors), a business partner, a contractor who serves as 
the "legal department," an "MD Reporting" employee, and the business development assistant. The 
chart further shows that the business development assistant supervises an art director located in 
Egypt and a client service assistant located in UAE. 
The Petitioner provided a lengthy list of duties for the business development assistant, indicating that 
she performs clerical, administrative and office-related duties, as well as researching and cold calling 
potential clients, creating presentations, developing solutions for clients, and interacting daily with a 
"Project Director" and "the internal team" regarding projects on a daily basis. In addition, the 
Petitioner submitted evidence of wages paid to this employee, as well as to its previous employees, 
and copies of IRS Form 1099-MISC, Miscellaneous Income, issued to three contractors in 2015 in 
amounts ranging from $1000 to $3938.68. 
One of these contractors was CEO of who provided a letter 
dated December 16, 2015, explaining that he has accepted an offer to succeed the Beneficiary in the 
Petitioner's managing director position in two years, and would be working with the Petitioner on a 
contracting basis and reporting to the Beneficiary in order to prepare for the assignment. 
Upon review of the record, we find insufficient evidence to establish that the Petitioner has grown to 
the point during its initial year of operations where it could support the Beneficiary in a managerial 
or executive pos1t10n. The statutory definition of the term "executive capacity" focuses on a 
person's elevated position within a complex organizational hierarchy, including major components 
or functions of the organization, and that person's authority to direct the organization. Section 
101(a)(44)(B) of the Act, 8 U.S.C. § 1101(a)(44)(B). Under the statute, a beneficiary must have the 
ability to "direct the management" and "establish the goals and policies" of that organization. 
Inherent to the definition, the organization must have a subordinate level of managerial employees 
for a beneficiary to direct and a beneficiary must primarily focus on the broad goals and policies of 
the organization rather than the day-to-day operations of the enterprise. An individual will not be 
deemed an executive under the statute simply because they have an executive title or because they 
"direct" the enterprise as an owner or sole managerial employee. A beneficiary must also exercise 
Matter of747G- LLC 
"wide latitude in discretionary decision making" and receive only "general supervision or direction 
from higher level executives, the board of directors, or stockholders of the organization." !d. 
Here, while we do not doubt that the Beneficiary has the appropriate level of authority and allocates 
some of his time to qualifying executive duties, the record does not support a finding that he would 
be primarily focused on the broad goals and policies of the company or that he would be sufficiently 
relieved from involvement in the day-to-day operations of the company. As noted, the Petitioner 
indicated that more thah half of the Beneficiary's time would be allocated to business development, 
marketing and promotion of the company, and financial matters. While some of these duties would 
likely involve discretionary decision-making authority consistent with an executive position, the 
Petitioner has not established that the company's employees or contractors relieve the Beneficiary 
from significant involvement in non-executive functions of the company. Accordingly, the 
Petitioner has not established that he would be employed in an executive capacity. 
Although the Petitioner consistently states that the Beneficiary's position would be in an executive 
capacity, we have also considered whether the evidence supports a finding that his position would 
qualify as managerial. The statutory definition of "managerial capacity" allows for both "personnel 
managers" and "function managers." See sections 101(a)(44)(A)(i) and (ii) 9f the Act. Personnel 
managers are required to primarily supervise and control the work of other supervisory, professional, 
o~ managerial employees. The statute plainly states that a "first line supervisor is not considered to 
be acting in a managerial capacity merely by virtue of the supervisor's supervisory duties unless the 
employees supervised are professional." Section L01(a)(44)(A) of the Act; 8 C.F.R. 
§ 214.2(1)(1 )(ii)(B)( 4). If a petitioner claims that a beneficiary directly supervises other employees, 
those subordinate employees must be supervisory, professional, or managerial, and the beneficiary 
must have the authority to hire and fire those employees, or recommend those actions, and take other 
personnel actions. Sections 101(a)(44)(A)(ii)-(iii) ofthe Act; 8 C.F.R. §§ 214.2(1)(1)(ii)(B)(2)-(3). 
Here, while the Beneficiary directly supervised two employees at the time of filing, the Petitioner 
allocated only 10 percent of his time to personnel matters. Further, both employees left the company 
while the petition was pending and there is no evidence that the Petitioner intends to staff these 
positions again in the future. The Petitioner must establish eligibility at the time of filing the 
nonimmigrant visa petition and must continue to be eligible for the benefit through adjudication. 
8 C.F.R. § 103.2(b)(l). At the time the RFE was issued, and for the three months preceding that 
date, the Beneficiary was the Petitioner's sole employee and was clearly not acting as a personnel 
manager. While we acknowledge that the Petitioner eventually hired a business development 
assistant, a review of her job duties reflects that this position is not managerial or supervisory in 
nature and the Petitioner, which on appeal characterizes this position as an "administrative 
assistant," has neither claimed nor provided evidence that it is a professional position.1 
1 To determine whether the Beneficiary manages professional employees, we must evaluate whether the subordinate 
positions require a baccalaureate degree as a minimum for entry into the field of endeavor. Cf 8 C.F.R. § 204.5(k)(2) 
(defining "profession" to mean 'tany occupation for which a United States baccalaureate degree or its foreign equivalent 
·is the minimum requirement for entry into the occupation"). Section IOI(a)(32) of the Act, 8 U.S.C. § IIOI(a)(32), 
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Matter o.f747G- LLC 
The Petitioner has not established, in the alternative, that the Beneficiary will be employed primarily 
as, a "function manager." The term "function manager" applies generally when a beneficiary does 
not supervise or control the work of a subordinate staff but instead is primarily responsible for 
managing an "essential function" within the organization. See section 101(a)(44)(A)(ii) ofthe Act. 
The term "essential function" is not defined by statute or regulation. If a petitioner claims that a 
beneficiary will manage an essential function, a petitioner must clearly describe the duties to be 
performed in managing the essential function, i.e., identify the function with specificity, articulate 
the' essential nature of the function, and establish the proportion of a beneficiary's daily duties 
dedicated to managing the essential function. See 8 C.F.R. § 214.2(1)(3)(ii). In addition, a 
petitioner's description of a beneficiary's daily duties must demonstrate that the beneficiary will 
manage the function rather than perform the duties related to the function. Here, the Petitioner 
acknowledges that the Beneficiary has only one subordinate as of the date of the appeal, but it has 
not articulated a claim that the Beneficiary would primarily manage an essential function, nor does 
its description of the Beneficiary's duties reflect that his duties would be allocated primarily to 
managing an essential function or otherwise primarily performing managerial duties. 
On appeal, the Petitioner further refers to unpublished decisions in which we determined that the 
beneficiary met the requirements of serving in a managerial and executive capacity for L-1 
classification even though he was the sole employee or responsible for supervising a very small staff. 
The Petitioner has not established evidence to establish that the facts of the instant petition are 
analogous to those in the unpublished decisions. While 8 C.F.R. § 103.3(c) provides that AAO 
precedent decisions are binding on all USCIS employees in the administration of the _Act, 
unpublished decisions are not similarly binding. 
We acknowledge that a company's size alone, without taking into account the reasonable needs of 
the organization, may not be the determining factor in denying a visa petition for classification as a 
multinational manager or executive. See section 101(a)(44)(C) of the Act, 8 U.S.C. 
§ 1101(a)(44)(C). However, it is appropriate for USCIS to consider the size of the petitioning 
company in conjunction with other relevant factors, such as the absence of employees who would 
perform the non-managerial or non-executive operations of the company, or a "shell company" that 
does not conduct business in a regular and continuous manner. See, e.g., Family Inc. v. USCIS, 469 
F.3d 1313 (9th Cir. 2006); Systronics Corp. v. INS, 153 F. Supp. 2d 7, 15 (D.D.C. 2001). 
Here, the Petitioner employed between zero and two part- and full-time workers subordinate to the 
Beneficiary while the petition was pending. The Petitioner states that it relies primarily on 
contractors rather than traditional employees to perform the company's functions. While it has 
submitted some evidence related to its contractors, including evidence of limited payments made to 
them in 2015, it has also stated that it useS' them for short-term projects and has not provided a 
detailed description of the services each contractor actually provides or evidence that the contractors 
are substantially involved in the day-to-day operations of the business rather than providing certain 
states that "[t]he term profession shall include but not be limited to architects, engineers, lawyers, physicians, surgeons, 
and teachers in elementary or secondary schools, colleges, academies, or seminaries." 
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Matter of747G- LLC 
services to clients on an as-needed basis. Similarly, the Petitioner identifies two foreign employees 
on its organizational chart, but, again, did not provide a description of their duties or evidence that 
they are providing services for the U.S. company. Going on record without supporting documentary 
evidence is not sufficient for purposes of meeting the burden of proof in these proceedings. Matter 
ofSojjici, 22 I&N Dec. 158, 165 (Comm'r 1998) (quoting Matter ofTreasure Craft ofCal., 14 I&N 
Dec. 190 (Reg'l Comm'r 1972)). 
The regulations governing new office extensions require USCIS to examine the organizational 
structure and staffing levels of the petitioner at the end of its initial year of operation. See 8 C.F .R. § 
214.2(1)(14)(ii)(D). The regulation at 8 C.F.R. § 214.2(1)(3)(v)(C) only allows the "new office" 
operation one year within the date of approval of the petition to support an executive or managerial 
position. There is no provision in USCIS regulations that allows for an extension of this one-year 
period. If a business does not have the necessary staffing after one year to relieve the beneficiary 
from performing operational and administrative tasks, the Petitioner is ineligible by regulation for an 
extension. Here, while the record shows that the company has expanded in terms of revenue and 
number of clients, the Petitioner has not submitted sufficient evidence that the combination of an 
administrative assistant, several short-term contractors, and the claimed foreign staff would 
sufficiently relieve the Beneficiary from performing non-executive and non-managerial duties 
associated with growing and administering the business and overseeing and executing projects in 
multiple countries. Further, at the time of filing, the Petitioner employed a full-time client service 
manager and the record that does not indicate that his duties have been assigned to the assistant who 
was hired later, or to one or more contractors. As such, it is unclear who, if not the Beneficiary, is 
available to perform the non-qualifying duties previously assigned to this employee. 
Based on the deficiencies discussed above, the Petitioner has not established that the Beneficiary 
will be employed in a managerial or executive capacity under the extended petition. 
III. CONCLUSION 
The petition will be denied and the appeal dismissed for the above stated reason. In visa petition 
proceedings, the burden of proving eligibility for the benefit sought remains with the petitioner. 
Section 291 of the Act, 8 U.S.C. § 1361; Matter of Otiende, 26 I&N Dec. 127, 128 (BIA 2013). 
Here, that burden has not been met. 
ORDER: The appeal is dismissed. 
Cite as Matter of747G- LLC, ID# 76179 (AAO Oct. 21, 2016) 
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