sustained L-1A Case: Logistics

U.S. Citizenship 
and Immigration 
Services 
MATTER OF S-, LLC 
Non-Precedent Decision of the 
Administrative Appeals Office 
DATE: FEB. 28, 2018 
APPEAL OF CALIFORNIA SERVICE CENTER DECISION 
PETITION: FORM I-129, PETITION FOR A NONIMMIGRANT WORKER 
The Petitioner, a third party logistics provider, seeks approval of its amended blanket petition 1 to 
facilitate the transfer of future beneficiaries under the L-1 nonimmigrant classification for intracompany 
transferees. See Immigration and Nationality Act section 101(a)(15)(L), 8 U.S.C. § 1101(a)(15)(L). 
The L-1 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, 
executive, or specialized knowledge capacity. A petitioner may file a blanket petition to seek 
continuing approval of itself and some or all of its parent, branches, subsidiaries, and affiliates as 
qualifying organizations if the petitioner and each of those entities are engaged in commercial trade or 
services, and if certain other requirements are met. See 8 C.F .R. § 214.2(1)( 4)(i). 
The Director of the California Service Center approved the petition in part, but determined that the 
Petitioner did not establish its qualifying relationship with one of the foreign entities it sought to add 
to its approved blanket L listing. In these circumstances, the regulations require U.S. Citizenship 
and Immigration Services to issue a denial decision explaining the reasons for the partial denial, and 
to issue an approval notice that includes only the entities determined to have a qualifying 
relationship with the petitioner. See 8 C.F.R. § 214.2(1)(7)(1)(8)(3). 
In this matter, however, the Director included all requested entities on the approval notice and struck 
out the entity deemed to be a non-qualifying entity. This alteration was handwritten in pen with the 
annotation "not included." The Director did not issue a separate denial notice explaining why this 
entity, a Vietnamese company which the Petitioner identified as its wholly-owned indirect 
subsidiary, was excluded. We will treat the Director's actions as a partial denial of the petition for 
the purposes of adjudicating the Petitioner's appeal. 
On appeal, the Petitioner points out the Director's procedural error in failing to issue a denial notice 
explaining the partial denial of the petition. In addition, it raises concerns about its ability to use an 
approval notice bearing handwritten notations. Finally, the Petitioner asserts that it provided ample 
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The Petitioner already has an approved blanket L petition with indefinite validity and sought to add four additional 
qualifying organizations to its approved list. See 8 C.F.R. § 214.2(l)(7)(i)(C) (stating that a petitioner must file an 
amended petition to reflect additional qualifying organizations under a blanket petition). 
Matter of S-, LLC 
evidence that all of the newly added entities, including the one stricken from the approval notice, are 
qualifying entities that are engaged in commercial trade or services. 
Upon de novo review, we will sustain the appeal. The Petitioner has provided ample evidence that 
the Vietnamese entity in question is a wholly-owned subsidiary of the Petitioner's acknowledged 
Chinese subsidiary. Further, the Petitioner has submitted relevant documentation, including invoices 
for services rendered and bank statements showing extensive activity, to establish that the 
Vietnamese subsidiary was engaged in commercial trade or services at the time this petition was 
filed. 
If a director's decision to deny a blanket L petition is denied, in part, and such a decision is reversed 
on appeal, the regulations require that "a new Form I-797 shall be sent to the petitioner to reflect the 
changes made as a result of the appeal." 8 C.F.R. § 214.2(1)(7)(1)(B)(3). 
The petitioner has established that all entities for which blanket approval is sought are qualifying 
organizations. Accordingly, the Director is instructed to issue a new Form I-797 Approval Notice 
reflecting all entities requested by the Petitioner in its amended petition filing. 
ORDER: The appeal is sustained. 
Cite as Matter ofS-, LLC, ID# 965132 (AAO Feb. 28, 2018) 
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