remanded L-1A Case: Network Software

U.S. Citizenship 
and Immigration 
Services 
Non-Precedent Decision of the
Administrative Appeals Office 
Date: JAN. 23, 2024 In Re: 29607586 
Appeal of California Service Center Decision 
Form 1-129, Petition for Blanket L Approval 
The Petitioner, a developer and distributor of network software tools, had a blanket petition approved 
to facilitate the transfer of future beneficiaries under the L-1 nonimmigrant classification for 
intracompany transferees . Section 10l(a)(l5)(L) of the Immigration and Nationality Act (the Act)), 
8 U.S.C. § l 101(a)(l5)(L) and section 214(c)(2)(A) of the Act, 8 U.S.C. § 1184. 
The Director of the California Service Center revoked the approval of the petition, concluding that the 
Petitioner did not use the blanket petition procedure to transfer employees outside of the United States 
"for three consecutive years" and was subject to revocation pursuant to 8 C .F.R. 
§ 214.2(1)(9)(iii)(A)(6). The matter is now before us on appeal. 8 C.F.R. § 103.3. 
The Petitioner bears the burden of proof to demonstrate eligibility by a preponderance of the evidence. 
Matter ofChawathe, 25 I&N Dec. 369, 375-76 (AAO 2010). We review the questions in this matter 
de novo. Matter of Christo 's, Inc., 26 l&N Dec. 537, 537 n.2 (AAO 2015). Upon de novo review, 
we will withdraw the Director's decision and remand the matter for entry of a new decision consistent 
with the following analysis. 
I. LAW 
Section 214(c)(2)(A) of the Act authorizes a procedure under which a qualifying employer may file a 
blanket petition to facilitate the transfer of L-1 intracompany transferees as an alternative to filing of 
individual petitions on behalf of such employees. A blanket L approval notice lists U.S. and foreign 
qualifying organizations within a petitioner's business group, eliminating the need to establish a 
qualifying relationship in individual cases. 8 C.F.R. § 214.2(1)(4)(iii). Blanket L approval allows 
petitioners to submit nonimmigrant petitions (on Forms I-129S) for managers, executives, and 
specialized knowledge professionals directly to U.S. consulates or certain border officials. 8 C.F.R. 
§ 214.2(1)(5). 
A petitioner may file a blanket L petition if: (1) the petitioner and each of the listed entities engage in 
commercial trade or services; (2) the petitioner has an office in the United States that has been doing 
business for at least one year; (3) the petitioner has three or more domestic and foreign branches, 
subsidiaries, or affiliates; and ( 4) the petitioner and the other listed qualifying organizations: have 
obtained approval of petitions for at least ten "L" managers, executives, or specialized knowledge 
professionals during the previous 12 months; have U.S. subsidiaries or affiliates with combined annual 
sales of at least $25 million; or have a U.S. work force of at least 1,000 employees. 8 C.F.R. 
§ 214.2(1)(4)(i). 
In addition, U.S. Citizenship and Immigration Services may revoke approval of an L-lA petition under 
six specific circumstances. 8 C.F.R. § 214.2(1)(9)(iii)(A). To properly revoke the approval of a 
petition, a director must issue a notice of intent to revoke that contains a detailed statement of the 
grounds for the revocation and the time period allowed for rebuttal. 8 C.F.R. § 214.2(1)(9)(iii)(B). 
II. ANALYSIS 
As previously noted, the Director revoked the approval of the pet1t10n pursuant to 8 C.F.R. 
§ 214.2(1)(9)(iii)(A)(6), which states that a notice of intent to revoke "shall" be issued if "[n]one of 
the qualifying organizations in a blanket petition have used the blanket petition procedure for three 
consecutive years." 
Although the Director issued a notice of intent to revoke notifying the Petitioner of the basis for the 
intended revocation, the record at hand shows that the blanket petition was approved with an assigned 
validity period of July 9, 2020, until February 19, 2023, for a total of two years and seven months. 
Because the original validity period was for less than three years, the record before us does not support 
the Director's determination that the Petitioner's blanket approval is subject to revocation on notice 
pursuant to 8 C.F.R. § 214.2(1)(9)(iii)(A)(6) for not using the blanket petition for three consecutive 
years. 1 We therefore cannot affirm the Director's decision. The Director did not indicate any other 
grounds for revocation. Following review, the Director should identify any additional grounds in a 
new notice or should take appropriate action in accordance with the foregoing on remand. 
ORDER: The Director's decision is withdrawn. The matter is remanded for the entry of a new 
decision consistent with the foregoing analysis. 
1 Documents outside the record show that the Petitioner filed several individual Forms 1-129, Petition for a Nonimmigrant 
Worker, including two in April and June 2023. 
2