dismissed L-1A Case: Property Management And Equine Investment

U.S. Citizenship 
and Immigration 
Services 
MATTER OF W-C-L-B&B, INC. 
APPEAL OF VERMONT SERVICE CENTER DECISION 
Non-Precedent Decision of the 
Administrative Appeals Office 
DATE: JAN.l9,2018 
PETITION: FORM I-129, PETITION FOR A NONIMMIGRANT WORKER 
The Petitioner, which intends to engage in property management and equine investment, seeks to 
temporarily employ the Beneficiary as the vice president of its new oflice 1 under the L-1 A 
nonimmigrant classification for intracompany transferees. See Immigration and Nationality Act (the 
Act) section IOI(a)(l5)(L), 8 U.S.C. § IIOI(a)(l5)(L). TheL-IA 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 of the Vermont Service Center denied the petition. concluding that the Petitioner did 
not establish, as required, that the Beneficiary has been employed abroad in a managerial or executive 
capacity, or that the Petitioner would be able to support a managerial or executive position within one 
year of approval of the petition. 
On appeal, the Petitioner submits additional evidence and asserts that its prior counsel was "not 
strong enough to establish the eligibility of our beneficiary." The Petitioner contends that the 
Beneficiary was employed abroad and would be employed in the United States in an executive 
capacity. 
Upon de novo review, we will dismiss the appeal. 
I. LEGAL FRAMEWORK 
To establish eligibility tor the L-IA nonimmigrant visa classification tor a new office, a qualifying 
organization must have employed the beneficiary in a managerial or executive capacity tor one 
continuous year within three years preceding the beneficiary's application for admission into the 
United States. 8 C.F.R. § 214.2(1)(3)(v)(B). 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 or executive capacity. Section I 01 (a)( 15)(L) of the 
Act. The petitioner must also establish that the beneficiary's prior education, training, and 
1 
The term "new office" refers to an organization which has been doing business in the United States for less than one 
year. 8 C.F.R. § 214.2(1)(1 )(ii)(F). The regulation at 8 C.F.R. § 214.2(1)(3)(v)(C) allows a "new office'' operation no 
more than one year within the date of approval of the petition to support an executive or managerial position. 
Matter r?fW-C-L-B&B, Inc. 
employment qualifies him or her to perform the intended services in the United States. 8 C.F.R. 
§ 214.2(1)(3). 
The petitioner must submit evidence to demonstrate that the new office will be able to support a 
managerial or executive position within one year. This evidence must establish that the petitioner 
secured sufficient physical premises to house its operation and disclose the proposed nature and 
scope of the entity, its organizational structure, its financial goals, and the size of the U.S. 
investment. See generally, 8 C.F.R. § 214.2(1)(3)(v). 
The term "executive capacity" is defined as an assignment within an organization in which the 
employee primarily directs the management of the organization or a major component or function of 
the organization; establishes the goals and policies of the organization, component, or function; 
exercises wide latitude in discretionary decision-making; and receives only general supervision or 
direction from higher-level executives, the board of directors, or stockholders of the organization. 
Section 10l(a)(44)(B) ofthe Act. 
II. EMPLOYMENT ABROAD IN AN EXECUTIVE CAPACITY 
The Director determined that the Petitioner did not establish that its claimed foreign affiliate 
employed the Beneficiary in a managerial or executive capacity. 2 The Director found that the 
submitted position description was too vague to establish what the Beneficiary actually did on a day­
to-day basis while employed abroad, and noted that there was a discrepancy in the record with 
respect to her position within the foreign entity's organizational hierarchy. 
On appeal, the Petitioner asserts that the Beneficiary was employed abroad in an executive capacity 
and claims that its former counsel did not provide a sufficient response to the Director's request for 
evidence (RFE). The Petitioner also submits additional evidence pertaining to the Beneficiary's 
foreign employment, including an undated employment contract, a revised job description, the 
foreign entity's payroll records from 2016, and business documents bearing the Beneficiary's 
signature as the foreign entity's authorized representative. 
A. Employment Capacity 
When examining the executive capacity of a given beneficiary, we will review the petitioner's 
description of the job duties. The petitioner's description of the job duties must clearly describe the 
duties performed by the beneficiary. See 8 C.F.R. § 214.2(1)(3)(ii). Beyond the required description 
of the job duties, U.S. Citizenship and Immigration Services (USCIS) examines 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. 
' Although the Director referenced the definitions of both managerial and executive capacity, the Petitioner claims that 
the Beneficiary was employed abroad in an executive capacity. 
2 
Maller ofW-C-L-B&B, Inc. 
However, in this case the Petitioner has provided conflicting job titles and job descriptions for the 
Beneficiary and inconsistent information regarding her placement within the foreign entity's 
organizational hierarchy. These inconsistencies prevent us from determining the true nature of her 
employment abroad and preclude a finding that she performed primarily executive duties. 
The Petitioner stated on the Form I-129 that the foreign entity employed the Beneficiary from June 
2012 until March 2014.3 In its initial supporting letter, the foreign entity's president stated that the 
Beneficiary held an unspecified executive position in which she established financial and operational 
reporting policies; reviewed financial and operational reports for compliance; established cash flow 
management policies; established the company's operational and financial goals; met with other 
industry executives to gain insight into pricing; and reviewed the execution of financial budgets. 
The Petitioner did not provide an organizational chart at the time of tiling; however, according to the 
Beneficiary's individual monthly payroll record for March 2013 to March 2014, she worked in the 
"administrative department" with a basic salary of Bs.4500. 
In response to the Director's RFE, the Petitioner indicated that the Beneficiary held the position of 
controller while employed abroad. It provided the employment contract and position description for 
her claimed successor in that position. An accompanying organizational chart depicted the 
controller position as senior to the company president, reporting only to the foreign entity's board of 
directors.4 
In the denial decision, the Director found that the duties provided for the controller position were too 
general to establish the Beneficiary's employment abroad in a managerial or executive capacity. 
The Director also noted that there was an apparent inconsistency regarding the Beneficiary's 
placement within the organizational hierarchy. Specifically, the Director noted that the 
Beneficiary's payroll records showed that she worked in the foreign entity's administrative 
department, while the organizational chart depicted her role as a senior employee reporting only to 
the board of directors. 
On appeal, the Petitioner generally claims that its prior counsel did not submit a strong response to 
the RFE, and provides additional evidence, which includes: 
• An undated employment contract between the Beneficiary and the foreign entity 
indicating that she was hired to serve in the position of "General Manager in the 
Management Area'' with responsibility for supervising all administration, human 
resources and operations activities; 
3 
At the time of filing in May 2016, the Beneficiary had been physically present in the United States since March 20, 
2014. 
4 
The foreign entity's January 2016 employee list, submitted at the time of filing, did not include a "controller" position. 
3 
Matter ojW-C-L-B&B, Inc. 
• An organizational chart which lists the Beneficiary as general manager. reporting 
to a vice president and supervising, directly or indirectly, all foreign entity staff. 
including subordinate managers 5; 
• A duty description for the general manager position; 
• The foreign entity's personnel list as of January 2014 which identifies the 
beneficiary as the general manager in the management department; 
• A new "individual monthly payroll detail" for the Beneficiary which indicates 
that she held worked in the management department from June 2012 until 
December 2014 with a monthly salary ranging from Bs.25,000 to Bs. 40,000; and 
• Foreign entity business ostensibly documents signed by the Beneficiary during the 
second halfof2014. 
The Petitioner does not explain why it previously claimed the Beneficiary served as the foreign 
entity's controller if she was actually the general manager. If she was the general manager, as stated 
by the foreign entity's president on appeal, it is unclear why he did not simply state this in his letter 
submitted at the time of filing. The position description provided at the time of filing bears no 
resemblance to the newly submitted general manager job description. On appeal, a petitioner cannot 
materially change a position's title, its level of authority within the organizational hierarchy, or the 
associated job responsibilities. A petitioner may not make material changes to a petition in an etfort 
to make a deficient petition conform to USCIS requirements. See Matter olfzummi, 22 I&N Dec. 
169, 176 (Assoc. Comm'r 1998). 
The Petitioner also has not addressed why the two payroll details submitted for the Beneficiary show 
vastly different salaries for the same period of employment, as well as different assigned 
departments. Further, the Petitioner does not indicate how the Beneficiary signed invoices and 
purchase orders on behalf of the foreign entity in Venezuela while residing in the United States in 
the latter portion of 2014. In fact, the Petitioner previously indicated that her employment with the 
foreign entity ended in March 2014. 
The Petitioner must resolve inconsistencies in the record with independent, objective evidence 
pointing to where the truth lies. Matter of' Ho, 19 I&N Dec. 582, 591-92 (BIA 1988). Unresolved 
material inconsistencies may lead us to reevaluate the reliability and sufficiency of other evidence 
submitted in support of the requested immigration benefit. !d. 
The evidence submitted on appeal does not resolve the deficiencies or inconsistencies noted by the 
Director. Rather, the new evidence introduces even more significant inconsistencies into the record. 
The Petitioner has not established that the Beneficiary actually held the position of general manager. 
a position it attributes to her for the first time on appeal. Further, the Petitioner now appears to have 
abandoned its earlier claim that she held the position of controller, a position that is not consistently 
depicted as part of the foreign entity's organizational structure. As a result, the Petitioner has not 
provided us with a credible job description or organizational chart to evaluate. 
5 
This version of the chart does not include a controller position. 
4 
Matter of W-C-L-B&B. Inc. 
The Petitioner has not provided consistent, credible information or evidence establishing the nature 
of the Beneficiary's duties with the foreign entity or her placement within the foreign entity's 
organizational hierarchy. Therefore, it has not met its burden to establish that she was employed 
abroad in an executive capacity. 
B. One Year of Employment Abroad 
Although not addressed by the Director, the Petitioner has not established that the Beneficiary had at 
least one year of continuous full-time employment abroad in the three years preceding the tiling of 
this petition, as required by 8 C.F.R. § 214.2(1)(3)(iii). 
Periods of time spent in the United States in lawful status for a branch of the same employer or a 
parent, affiliate, or subsidiary thereof, and brief visits to the United States for business or pleasure, 
are not interruptive of the one year of continuous employment abroad but such periods are not 
counted towards fulfillment of that requirement. See 8 C.F.R. § 214.2(1)(l)(ii)(A). 
As noted, at the time of filing, the Beneficiary had been in the United States continuously for 26 
months. The Beneficiary entered the United States on a B-2 visa in March 2014, received an 
extension of that status until March 2015, was denied a change of status from B-2 to L-1A in July 
2015, and remained in the United States when this petition was filed in May 2016. 
The Petitioner indicated on the Form I-129 that her employment with the foreign entity ended in 
March 2014. Even if the foreign entity continued to pay her salary thereafter, her one year of 
employment abroad must have occurred outside the United States between May 2013 and May 2016. 
The Beneficiary had no more than ten months of employment outside the United States during this 
period and cannot meet this requirement. For this additional reason, the petition cannot be approved. 
III. U.S. EMPLOYMENT IN AN EXECUTIVE CAPACITY 
The Director further determined that the Petitioner did not establish that its new office would be able 
to support an executive position within one year of approval of the petition. 
In the denial decision, the Director emphasized that the Petitioner's business plan was lacking 
information regarding the company's anticipated business benchmarks for the first year of operations 
and did not provide sufficient support, such as market data or industry research, for the company's 
projected growth. The Director further found that the Petitioner's description of the Beneficiary's 
proposed duties was vague and did not show how she would function at an executive level within 
one year. 
On appeal, the Petitioner asserts that the Beneficiary will be employed in a qualifying capacity and 
that the Director appears to have erroneously denied the petition due to "the large gaps of 
information" contained in the RFE response prepared by former counsel. The Petitioner submits an 
updated three-year business plan and asserts that the company has the strength "to continue and 
sustain our beneficiary immediately.'' The Petitioner also provides additional evidence related to 
5 
Matter ofW-C-L-B&B, Inc. 
real estate transactions undertaken by several claimed U.S. affiliates, as well as reference letters 
from various business associates. 
In the case of a new office petition, beyond the description of a beneficiary's proposed job duties, we 
review the petitioner's business and hiring plans and evidence that the business will grow 
sufficiently to support a beneficiary in the intended managerial or executive capacity. A petitioner 
has the burden to establish that it would realistically develop to the point where it would require the 
beneficiary to perform duties that are primarily managerial or executive in nature within one year. 
Accordingly, the totality of the evidence must be considered in analyzing whether the proposed 
managerial or executive position is plausible considering a petitioner's anticipated staffing levels and 
stage of development within a one-year period. See 8 C.F.R. § 214.2(1)(3)(v)(C). 
A. Projected Staffing and Business Plan 
The Petitioner indicated at the time of filing that its core activity will be the purchase. training. 
racing, and sale of thoroughbred horses. Specifically, the Petitioner indicates that it will purchase 
yearling foals and train its horses for racing alongside other foals entrusted to its care by third 
parties, who will pay the Petitioner fees and commissions. The Petitioner then intends to sell its 
two-year old horses at auctions for a profit. In addition, the Petitioner indicates that it will provide. 
as a "collateral business" a residential real estate management service for properties owned by 
affiliated companies and third parties. 
The Petitioner indicated that it would hire a total of 16 employees during its first year of operations. 
These employees would include: the Beneficiary (vice president); a general manager; an equine 
operations manager who will supervise a race horse trainer, two exercise riders, an operations and 
logistics supervisor and three grooms; and a real estate and equine facilities manager, who will 
supervise a handyman, a "tenant, landlord, horse owner services clerk", and a "payments and record 
keeping clerk." The Petitioner also identified several contractors including equine supply vendors, a 
boarding facility, equine transportation providers, event subcontractors, and veterinary service 
providers. 
The Petitioner's business plan indicates that it anticipates $685.622 in revenue from its equine 
division (from the sale of its own horses and management fees for horses owned by others) and 
$39,420 from its real estate division. It further indicates that the company would achieve over 
$250,000 in net income in its initial year. The Petitioner notes that, due to the nature of the business, 
it would operate at a loss for several months and states that it will receive a total of $200,600 in 
loans from the foreign affiliate and other "related entities'' but it did not further document the 
availability of these funds. 
The Petitioner submits a slightly revised business plan on appeal which indicates that the company 
"has invested in the business of buying and selling residential properties through its affiliates in 
order to self-manage and diversify our investments." The Petitioner notes that the Beneficiary 
directs these investments "through direct negotiations with the brokers," and notes that it acquired a 
total of eight residential properties since March 2013, some of which were rented and some which 
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Matter qfW-C-L-B&B , Inc. 
had been sold. The Petitioner provides a letter from a representative of 
who states that the Beneficiary is "the manager and the principal executive of the real estate 
companres and "as a divisions of [the 
Petitioner]" and notes that has had a commercial relationship with her since 2014. 
The Petitioner submits entity details tor 
all of which identify the Beneficiary as a company ofticer. However , the 
Petitioner does not provide evidence of ownership for these companies in support of its claim that 
they are "related entities" who will provide guaranteed income. 
While the Petitioner has provided a lengthy business plan and an organizational chart depicting 
multiple tiers of subordinates who would report to the Beneficiary , we agree with the Director that 
the business plan does not substantiate the feasibility of the Petitioner 's projected staffing and 
financial objectives. The Petitioner owned one horse at the time of filing and indicated it would 
purchase one horse monthly until it has six horses, with plans to board and train six third-party 
horses. The Petitioner also indicated that it owned one property, which would serve as the 
Beneficiary ' s residence in the United States . The Petitioner's most recent bank statement at the time 
of filing showed a balance of less than $1500. Given these facts, the Petitioner did not adequately 
support its claim that it would rapidly develop to the point where it would suppott a statT of 16 
people within a matter of months. 
Much of the business plan focuses on the Petitioner ' s specific methods tor the tra1nrng and 
maintenance of horses , but the plan is lacking specific details regarding how the company will 
develop from owning a single horse and one residential property to operating two fully-staffed 
divisions with revenues of over $700,000 in its initial year. The business plan includes a breakdown 
of revenue , costs, and expenses to show how it derived its projected net income figure; however. this 
portion of the plan is mostly illegible . 
The additional information submitted on appeal appears to add a third line of business to the 
company (buying and selling residential property), but the updated business plan does not include a 
revised staffing plan or any additional financial projections reflecting this line of business. In fact, 
the Petitioner does not indicate who, besides the Beneficiary, would be responsible for non­
executive duties related to this area of the business. 
We note that the updated business plan includes a photograph of the Beneficiary '·during a meeting 
with veterinarian, trainer and administrative personnel" from December 2016. However. the 
Petitioner did not provide evidence related to any employees hired while the petition was pending, 
which may have helped support the Petitioner's hiring plan. 
Finally , the record lacks job descriptions for the company's proposed employees and therefore does 
not contain sufficient information to show that the subordinate staff would relieve the Beneficiary 
from involvement in the day-to-day supervision and operations of the horse training and real estate 
businesses, so that she could perform primarily executive duties. 
Matter ofW-C-L-B&B, Inc. 
B. Duties 
At the time of filing, the Petitioner provided a lengthy duty description for the Beneficiary's 
proposed position of vice president. The Petitioner indicated that she will establish goals and 
policies related to foal training and competition, sales, insurance, personnel, subcontractor selection, 
independent audits, real estate management services, client services, veterinary care, and 
geographical expansion. 
In addition, the Petitioner stated that she will direct the management of the company by meeting 
regularly with the general manager, reviewing reports, performing on-site visits to training/boarding 
facilities and horse racetracks, providing direction to the general manager, reviewing audit reports, 
reviewing training and veterinary logs of individual horses, and reviewing performance metrics of 
the herd. Further, the Petitioner indicated that she would make decisions on matters requiring 
executive approval, such as approving variances in horse training plans, meeting with prospective 
and existing clients, authorizing changes in the commission and fee structure, making decisions 
regarding race venues and events, and reviewing all bank account statements. 
Finally, the Petitioner stated that she would receive only general direction from the company 
president, have the autonomy to establish and modify policies, make final decisions concerning 
legal, fiscal, or commercial actions, have the authority to hire and fire the general manager, and keep 
the president informed of company activities on a monthly basis. 
We agree with the Director's conclusion that the job description is too vague to establish that the 
Beneficiary's duties would be primarily executive in nature within one year. Even though the 
Petitioner indicates that the Beneficiary will have the executive authority to set goals and establish 
the company's policies, it is unclear how much time she will spend on these responsibilities once 
those initial company policies are in place. Similarly, the Petitioner's statement that she will receive 
minimal supervision and exercise authority to make decisions indicates her seniority within the 
organizational structure, but does not provide insight into the expected nature of her day-to-day tasks 
during and after the company's initial year of operations. Both of these broad responsibilities 
closely resemble the statutory definition of executive capacity. However, 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. 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 Assocs, 
Inc. v. Meissner, 1997 WL 188942 at *5 (S.D.?\I.Y.). 
The Petitioner indicated that the Beneficiary would be responsible for "directing the management of 
the company," but this area of responsibility included a number of non-executive duties. For 
example, the Petitioner stated that the Beneficiary will review training Jogs of individual horses, 
review veterinary logs, review performance metrics of the herd, and conduct on site visits. It did not 
explain how these duties qualify as executive in nature, or why they would not be delegated to a 
subordinate manager or supervisor in the equine line of the Petitioner's business. Similarly, the 
Petitioner indicates that the Beneficiary's responsibility to "exercise wide latitude in discretionary 
decision making" will include reviewing individual horse's training plans, reviewing bank account 
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Maller ufW-C-L-B&B, Inc. 
statements, and meeting with current and prospective clients. The Petitioner has not shown that 
these types of duties are executive in nature, rather than routine supervisory, financial, and sales and 
marketing duties. In fact, it is not clear whether other stafTwould be responsible for any interactions 
with prospective clients, as the company does not intend to employ any sales, marketing, or business 
development staff: and the Petitioner has not provided job descriptions for its proposed subordinate 
employees. 
Further, the new business plan submitted on appeal raises further questions regarding the nature of 
the Beneficiary's proposed duties. The initial job description provided for the Beneficiary 
mentioned the company's real estate business only in passing, and the Petitioner initially indicated 
that its activities would be limited to property management. On appeal, the Petitioner indicates that 
the company has "invested in the business of buying and selling residential properties" and indicates 
that the Beneficiary "directs" these investments. The Petitioner has not identified other statT that 
would assist the Beneficiary with this area of the business. In fact, the Petitioner provided evidence 
that the Beneficiary attended a course that is a pre-requisite for obtaining a Florida real estate 
license. Therefore, it is reasonable to believe that the Beneficiary's intended duties will include real 
estate functions that are not included in the position description the Petitioner provided. 
Similarly, the Petitioner's new business plan raises additional questions regarding the Beneficiary's 
intended level of day-to-day involvement in the horse training aspect of the business. The Petitioner 
outlines 20 tasks involved in the company's thoroughbred management service and indicates that the 
Beneficiary is or will be responsible for the management of these services, but the record does not 
identify who will be responsible for performing some of the underlying tasks. For example, the 
Petitioner indicates that the company will provide valuation assessments, advise clients on selection 
of new livestock, and assist clients in purchasing and/or bidding process for horses. It is unclear 
who would perform these duties and they cannot readily be attributed to any of the subordinate staff 
based on the very minimal information provided regarding their roles. 
The Petitioner has consistently stated that the Beneficiary will occupy the senior position in the new 
office, but has not submitted a job description or supporting evidence sufficient to demonstrate that 
she would primarily engage in executive duties, or that the new office would support an executive 
position, after the initial year of operations. 
IV. QUALIFYING RELATIONSHIP 
Although not addressed by the Director, the record does not contain sufficient evidence to establish 
that the Petitioner has a qualifying relationship with the Beneficiary's foreign employer. To 
establish a "qualifying relationship,'' the Petitioner must show that the Beneficiary's foreign 
employer and the proposed U.S. employer are the same employer (i.e. one entity with "branch" 
offices), or related as a ''parent and subsidiary" or as "affiliates.'' See section I 0 I (a)(l5 )(L) of the 
Act; see also 8 C.F.R. § 214.2(l)(l)(ii) (providing definitions of the terms "parent,'' "branch," 
"subsidiary," and "affiliate''). 
9 
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Matter C?fW-C-L-B&B. Inc. 
The Petitioner claims that it is an aftiliate of the Beneficiary's foreign employer, noting that 
owns 100% ofthe foreign entity and 50% of the U.S. entity , with the remaining 50% owned 
by the Beneficiary. The Petitioner provided sufficient evidence of ownership of the 
foreign entity, but did not adequately document the ownership of the U.S. company . 
As general evidence of a petitioner's claimed qualifying relationship, stock certificates alone are not 
sufficient evidence to determine whether a stockholder maintains ownership and control of a 
corporate entity. The corporate stock certificate ledger, stock certificate registry, corporate bylaws, 
and the minutes of relevant annual shareholder meetings must also be examined to determine the 
total number of shares issued , the exact number issued to the shareholder, and the subsequent 
percentage ownership and its effect on corporate control. In addition , a petitioning company must 
disclose all agreements relating to the voting of shares , the distribution of profit, the management 
and direction of the subsidiary , and any other factor affecting control of the entity. See Matter of 
Siemens Me d. Sys .. Inc., 19 I&N Dec. 362 (Comm 'r 1962). Without full disclosure of all relevant 
documents, we are unable to determine the elements of ownership and control. 
The Petitioner submitted 
the following stock certificates at the time of filing: 
Number 
00 
01 
Shares 
50 
50 
Owner 
Beneficiary 
Date 
March 17, 2016 
June 1, 2013 
On appeal, the Petitioner provides the following stock certificates, but does not include copies of the 
previously submitted certificates: 
Number 
04 
05 
06 
Shares 
60 
30 
10 
Owner 
Foreign entity 
Beneficiary 
Date 
May 24, 2013 
May 24,2013 
May 24,2013 
The stock certificates indicate that the company is authorized to issue I 00 shares, but based on the 
evidence submitted , it has actually issued at least 200 shares . It is unclear why the Petitioner would 
issue stock certificates numbers 00 and 01 subsequent to issuing numbers 04 through 06, and the 
Petitioner has not provided copies of all of its share certificates as necessary to fully document its 
current ownership and control. 
Here, the evidence does not corroborate the Petitioner's claimed ownership, and is insufficient to 
establish that the Petitioner has a qualifying relationship with the foreign entity. 
V. CONCLUSION 
The Petitioner has not established that the Beneficiary has been employed abroad in an executive 
capacity for at least one year in the three years preceding the filing of the petition , that it would 
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Matter ofW-C-L-B&B, Inc. 
employ her in an executive capacity within one year, or that it has a qualifying relationship with the 
Beneficiary's foreign employer. 
ORDER: The appeal is dismissed. 
Cite as Matter of W-C-L-B&B. Inc., 10# 929192 (AAO Jan. 19, 2018) 
11