dismissed L-1B Case: Pharmaceuticals

U.S. Citizenship 
and Immigration 
Services 
In Re: 4451893 
Non-Precedent Decision of the 
Administrative Appeals Office 
Date: FEB. 24, 2021 
Appeal of California Service Center Decision 
Form 1-129, Petition for L-lB Specialized Knowledge Worker 
The Petitioner, a developer and manufacturer of drug delivery devices, seeks to continue the 
Beneficiary's temporary employment as a "Business Development Manager" under the L-lB 
nonimmigrant classification for intracompany transferees. Immigration and Nationality Act (the Act) 
section 101(a)(15)(L), 8 U.S.C. § 1101(a)(15)(L). The L-lB classification allows a corporation or other 
legal entity (including its affiliate or subsidiary) to transfer a qualifying foreign employee with 
"specialized knowledge" to work temporarily in the United States. 
The Director of the California Service Center denied the petition, determining that the Petitioner did 
not establish, as required, that the Beneficiary possesses specialized knowledge, and that he would be 
employed in the United States in a specialized knowledge capacity. The matter is now before us on 
appeal. 
In these proceedings, it is the Petitioner's burden to establish eligibility for the requested benefit. See 
Section 291 of the Act, 8 U.S.C. § 1361. Upon de nova review, we conclude that the Petitioner has 
not met this burden. Accordingly, we will dismiss the appeal. 
I. LEGAL FRAMEWORK 
To establish eligibility for the L-lB nonimmigrant visa classification, a qualifying organization must 
have employed the beneficiary "in a capacity that is managerial, executive, or involves specialized 
knowledge," 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 specialized knowledge capacity. Id. The petitioner 
must also establish that the beneficiary's prior education, training, and employment qualify him or her 
to perform the intended services in the United States. 8 C.F.R. § 214.2(1)(3). 
11. BACKGROUND 
The Petitioner and its foreign affiliate design, develop, and manufacture drug delivery devices 
The Petitioner states 
that the Beneficiar is considered a " roduct specialist" with respect to the company's! I 
product, a patented designed for delivery ofl !prescription and 
over-the-counter...._ __ ~formulations. 
The Beneficiary completed a bachelor of commerce degree in international business in 2011 and 
received his Master of Business Administration (MBA) in organization and management studies in 
2012. The Petitioner's foreign affiliate hired the Beneficiary for the position of leads developer in 
October 2014.1 In December 2015, the Petitioner filed an L-lB petition to transfer the Beneficiary to 
the United States, where he initially held the position of account manager. The Petitioner states that 
the Beneficiary currently serves as a business development manager and seeks to continue his 
employment in this position at an annual salary of $73,645. 
111. SPECIALIZED KNOWLEDGE 
The primary issue before us whether the Petitioner established that the Beneficiary possesses 
specialized knowledge. 
The Director's decision focused on whether the proposed position of business development manager 
requires specialized knowledge and whether the Beneficiary had specialized knowledge at the time it 
filed this petition in August 2018. However, although the Petitioner requested an amendment and 
extension of the Beneficiary's L-lB status, it must establish that it met all requirements for this 
classification when it filed his initial L-1 petition. 8 C.F.R. § 214.2(I)(3)(iii).2 Specifically, the 
Petitioner must demonstrate that the Beneficiary had a full year of employment abroad in a position 
involving specialized knowledge and that he also possessed specialized knowledge with respect to the 
proffered position at the time it filed the prior L-lB petition on his behalf in December 2015. See 8 
C.F.R. §§ 214.2(1)(3)(ii)-(iv). 
Accordingly, as a threshold issue, we must determine whether the Petitioner established that the 
Beneficiary acquired the requisite specialized knowledge as a result of his education, training, and 14 
months of employment experience with its foreign affiliate. If a petitioner does not establish that a 
beneficiary possesses specialized knowledge, then we do not need to evaluate whether the position in 
the United States is in a specialized knowledge capacity, or if the position abroad involved specialized 
knowledge. 
A. Definition of Specialized Knowledge 
Under the statute, a beneficiary is deemed to have specialized knowledge if he or she has: (1) a 
"special" knowledge of the petitioning organization's product and its application in international 
1 The Petitioner submitted an organizational chart which identifies the Beneficiary's job title with the foreign affiliate as 
"Global Leads Developer," while the Beneficiary's payroll records for his entire period of employment abroad list his job 
title as "chargee de prospection junior" or "junior prospects officer." 
2 See also USCIS Policy Memorandum PM-602-0167, Satisfying the L-1 1-Year Foreign Employment Requirement; 
Revisions to Chapter 32.3 of the Adjudicator's Field Manual (AFM) 1 (Nov. 15, 2018), https://www.uscis.gov/laws/policy­
memoranda (noting that "the petitioner and the beneficiary must meet all requirements, including the 1 year of foreign 
employment, at the time the petitioner files the initial L-1 petition.") 
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markets; or (2) an "advanced" level of knowledge of the processes and procedures of the petitioning 
organization. Section 214(c)(2)(B) of the Act; 8 C.F.R. § 214.2(I)(1)(ii)(D). A petitioner may 
establish eligibility by submitting evidence that the beneficiary and the proffered position satisfy either 
prong of the definition. 
Specialized knowledge is also defined as knowledge possessed by an individual of the petitioning 
organization's product, service, research, equipment, techniques, management, or other interests and 
its application in international markets, or an advanced level of knowledge or expertise in the 
organization's processes and procedures. 8 C.F.R. § 214.2(I)(1)(ii)(D). 
As both "special" and "advanced" are relative terms, determining whether a given beneficiary's 
knowledge is "special" or "advanced" inherently requires a comparison of the beneficiary's 
knowledge against that of others. With respect to either special or advanced knowledge, the petitioner 
ordinarily must demonstrate that the beneficiary's knowledge is not commonly held throughout its 
industry and cannot be easily imparted from one person to another. The ultimate question is whether 
the petitioner has met its burden of demonstrating by a preponderance of the evidence that the 
beneficiary's knowledge or expertise is special or advanced, and that the beneficiary's position 
requires such knowledge. 
Once a petitioner articulates the nature of the claimed specialized knowledge, it is the weight and type 
of evidence which establishes whether the beneficiary actually possesses specialized knowledge. We 
cannot make a factual determination regarding a given beneficiary's specialized knowledge if the 
petitioner does not, at a minimum, articulate with specificity the nature of its products and services or 
processes and procedures, the nature of the specific industry or field involved, and the nature of the 
beneficiary's knowledge. The petitioner should also describe how such knowledge is typically gained 
within the organization and explain how and when the individual beneficiary gained such knowledge. 
B. Special Knowledge 
The Petitioner primarily claims that the Beneficiary possesses special knowledge of its organization's 
products and their application in international markets. 
Determining whether a beneficiary has "special knowledge" requires review of a given beneficiary's 
knowledge of how the petitioning organization manufactures, produces, or develops its products, 
services, research, equipment, techniques, management, or other interests. Because "special 
knowledge" concerns knowledge of the petitioning organization's products or services and its 
application in international markets, a petitioner may meet its burden through evidence that the 
beneficiary has knowledge that is distinct or uncommon in comparison to the knowledge of other 
similarly employed workers in the particular industry. 
Here, the Petitioner indicates that the Beneficiary gained his special knowledge of the Petitioner's 
I !product while employed by itsl laffiliate as a leads developer, a position he had held for 
approximately 14 months at the time the Petitioner filed the L-1B initial petition on his behalf. 
According to the foreign affiliate, the leads developer position involved: (1) identifying new business 
opportunities in targeted markets and segments, with a specific focus on the I I 
product; (2) performing leads qualification through cold calling, direct marketing campaigns, and trade 
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show contacts; (3) prioritizing and nurturing leads through direct contact to convert leads to qualified 
prospects; and (4) supporting the "specific Generics prospection plan." 
The foreign affiliate's representative emphasized that the Beneficiary was required to have 
"specialized in-depth knowledge of the I ] product intricacies ... in order to convey the 
distinctive advantages, efficacy, testing, and mechanisms of thesel Ito the high-level 
consumers within the pharmaceutical industry." The foreign entity also explained that the role 
required specialized knowledge of the pharmaceutical market, the company's custom CRM (customer 
relationship management) system, and experience with third-party tools such as Linkedln Sales 
Navigator, IMS, and Medtrack software, which the Beneficiary used to assist with market research, to 
allocate qualified leads to account managers, and to manage customer data and profiles to support 
sales force prospection. 
In sum, the Petitioner claims that the Beneficiary, as a result of his 14 months of employment with its 
foreign affiliate, possessed special knowledge of the group's proprietary products, sales strategies and 
processes, including tools and systems for prospecting new client for these products, as well as 
knowledge of the industry in which the Petitioner and its affiliate operate. 
Turning first to the Petitioner's claims regarding its products, the Petitioner has presented evidence 
that it has several patents for itsl I product and its components. The Petitioner submitted! I 
marketin materials which reflect that there are other~---~-~~designed for delivery 
ofL_ _______ ....r-_ .................... "'t'tions on the market. The Petitioner distinguishes its product 
by noting that it uses an venting system" and a I I valve system" to prevent 
contamination of th .__ __ ____.'s contents, while other manufacturers use a filter system in their 
I to achieve the same result. The Petitioner explains that its venting system can accommodate 
~a w-id-er~range ofl lthanl I that use a filter system. 
Although the Petitioner repeatedly emphasizes that its product is proprietary and unique in the 
industry, it must still establish that the knowledge required to develop sales leads for this product is 
truly distinct or uncommon in comparison to that generally held by similarly employed workers in the 
industry and that the Beneficiary was employed abroad in a position involving specialized knowledge. 
The Petitioner cannot meet its burden simply by claiming that the Beneficiary's knowledge is 
proprietary. For example, if a beneficiary's proprietary knowledge can be gained through a brief 
period of training or short period of experience with the company, then his or her knowledge of the 
company product generally will not qualify as special knowledge. 
Before addressing the Beneficiary's training history, we note that the Petitioner states on appeal that 
"it would take at least well over a year to train another worker in [the company's] proprietary product 
lines and processes, which would still not yield the lev~cialized knowledge that [the 
Beneficiary] gained as a result of working directly with thel___J product development team in 
I lwhile in the foreign position of Leads Developer." However, the Beneficiary himself had not 
worked for the foreign entity for "well over a year" at the time the Petitioner filed its initial petition to 
classify him as a specialized knowledge worker. In fact, he had been employed by the foreign entity 
for only 14 months at the time the Petitioner filed the prior petition on his behalf. 
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Turning to the Beneficiary's education, training, and experience, as noted, the record reflects that the 
Beneficiary completed his MBA in 2012 and joined the Petitioner's affiliate in October 2014. If he 
had any prior work experience in the pharmaceutical industry, or in business development or sales 
positions, it is not documented in the record. The Petitioner has also not indicated whether any related 
prior work experience is required for the leads developer position. It emphasized that the Beneficiary's 
academic coursework in marketing, management, communications, and business provided him with 
the foundational knowledge needed to perform the duties required of the position. 
The Petitioner indicates that, during his tenure as a leads developer overseas, the Beneficiary was 
"heavily involved as al I product specialist," that he completed an "exhaustive amount of 
product training" and "far more training inl lthan anyone else." The Petitioner states that, as a 
result of this training and specific focus onl I. the Beneficiary has knowledge of this product 
that is "uncommon and distinct from any other individual" employed by the foreign affiliate, by the 
U.S. company, or in the industry. 
The Petitioner provided a list of trainings reflecting that during his 14-month periol of emplloyment 
with its foreign affiliate,3 the Beneficiary completed the following trainings in the product 
during this period: 
I I t Microbiological studies and package (11/25/2014 - 1 hour) 
I I !platform (6 trainings between January 
2015 and December 2015, 11 hours in total) 
I §~ I manufacturing technology (9/25/2015 -1 hour) 
I Contracts (commercial perspective) (12/2/2015 -1.5 hours) 
I microbiological studies (12/3/2015 - 1 hour) 
We note that the training record reflects that the Beneficiary completed only 4.5 hours of I I­
specific training during his first six months of employment (November 2014 - April 2015), and 15.5 
hours in total. If he was able to fully perform his duties as~ I leads developer and be 
deemed a "product specialist" with only a half day to two days of training, then this undermines the 
Petitioner's claim that the "leads developer" role was a specialized knowledge position as claimed. In 
fact, the Beneficiary spent more time completing an external course in "prospecting over the phone" 
than he did receiving internal training in thel I product. Even if the Petitioner established that 
the Beneficiary had completed "far more training" inl lthan anyone else at the time of his 
transfer to the United States, we cannot conclude that product knowledge that can be conveyed through 
15 hours of training meets the standard of "special knowledge" of the company's proprietary product. 
With respect to either special or advanced knowledge, the petitioner ordinarily must demonstrate that 
a beneficiary's knowledge cannot be readily or easily imparted from one person to another in a short 
period of time. 
The record reflects that the Beneficiary's training with the foreign affiliate also included tours and 
presentations of the company's production plant and "Innovation Center for Devices," and training in 
more general topics such as intellectual property management, quality department processes, 
3 In addition to thJ !specific training, the Beneficiary completed approximately 90 hours of internal training and 
16 hours of external training in "prospecting over the phone." 
5 
technology and product management, trade shows, finance, supply agreements, confidential disclosure 
agreements, and "lean six sigma" training. The Petitioner did not provide sufficient information about 
this training to establish whether or how it contributed to the Beneficiary's claimed special knowledge. 
The remainder of the Beneficiary's training abroad involved training in the company's other product 
lines, notwithstanding the Petitioner's claim that each leads developer has specialized knowledge 
related to a particular product and that the Beneficiary was trained as al I specialist. 
Specifically, a statement from the foreign entity explained that another leads developer based at the 
foreign affiliate was specialized in developing sales leads for cl I product called I I 
and another focused on the company's line of ,__ ______ ___.devices. The foreign entity's 
representative explained that "the other Leads Developers had highly advanced, specialized 
knowledge in their own respective product lines and would be unable to perform the specialized duties 
of [the Beneficiary's] position, which is thel I product." 
We note that the other leads developers identified on the foreign entity's organizational chart both had 
the job title "Junior Leads Developer Temp." The fact that these individuals were hired as temporary 
employees further undermines the Petitioner's claim that all of its leads developers are trained to have 
"highly advanced, specialized knowledge" related to a specific product. It is unclear whether the other 
leads developers, like the Beneficiary, were cross trained in different product lines as the Petitioner 
did not provide information that would allow us to make this comparison. However, the record 
contains a chart that shows the number of targeted and qualified leads attributed to each leads 
developer in 2015 and it reflects that other leads developers were assigned qualified lead and sales 
targets tori I despite having different areas of specialization. 
In addition, although the Petitioner claims the Beneficiary's knowledge of thel I product is 
distinct and uncommon within the company, it did not provide information that would allow us to 
compare his knowledge with that possessed by others within the company's sales organization as a 
whole, and instead compared his knowledge only to the small staff of leads developers. The record 
reflects that once a leads developer qualifies a lead, responsibility for converting the lead into a sales 
opportunity is allocated to an account manager, busines
1 
develojment manager, or regional sales 
manager. Specifically, the Petitioner submitted a report on leads prepared by the Beneficiary 
in 2015 which shows that approximately 80 qualified leads had been assigned to 12 different sales 
staff for conversion to sales opportunities. Only two of these staff were identified on the organizational 
chart as serving in roles with a j I focus" but it is reasonable to conclude that all 12 had the 
necessary I I product knowledge to convert leads to sales.4 Even if we determined that the 
Beneficiary had greater knowledge of thd I product than the temporary junior leads developers 
in his department, we could not reach the same conclusion when comparing his knowledge to that of 
other staff within the sales organization. 
The Petitioner also attempts to differentiate the Beneficiary's knowledge by emphasizing that its U.S. 
based sales team "does not have special knowledge of thel lproduct line" because "they have 
never worked with thel I development team" inl I Specifically, on appeal, the Petitioner 
4 The leads developer position is described in the record as a "supporting role" within the sales organization, while the 
Petitioner's statements indicate that the business development manager role (which the Beneficiary currently holds) 
performs duties requiring greater technical knowledge of the company's proprietary products. 
6 
states that the Beneficiary "worked directly with the Technology Product Manager, Proeam Ma
1
ager, 
Automation Manager, Senior Desjan fngineer, and the Senior Design Engineers for all of 
whom are patent holders tori ' However, the Petitioner has not explained how or in what 
capacity the Beneficiary's role as a leads derloper relquired him to "work with" these individuals or 
how he was provided with knowledge of that was not otherwise available within the 
organization. It has provided supplemental affidavits from a U.S.-based regional sales director and 
I I business development manager ~al, and both of these individuals generally 
suggest that the Beneficiary's prior experience inL__Jmakes his knowledge special; however, these 
statements are similarly lacking in detail regarding the Beneficiary's role or interactions with the 
I !development team" and such interactions are not explained in the Petitioner's description of 
his duties abroad. 
We agree with the Petitioner that the Director erred by suggesting that the Beneficiary's knowledge is 
not "beyond or~ecause the evidence did not support a finding that he is an inventor or 
developer of thel___Jproduct. The Petitioner did not claim that the Beneficiary is a patent-holder 
and was not required to provide evidence in support of such a claim. There is no bright-line 
requirement that only a developer or inventor of a product can meet the standard of possessing special 
knowledge of that product. However, it is insufficient to broadly claim that the Beneficiary's 
knowledge is special because he "worked with" the developers in some unexplained capacity or that 
he was previously "based at [the company's~ headquarters inl lwhere continuous development 
and improvement of thd~-----~takes place." If he acquired knowledge apart from what 
was described and documented in his job description, job requirements, and training record, then it is 
the Petitioner's burden to explain and document when and how he gained this knowledge. 
Simply working at the same facility as the individuals who develop the product is not sufficient to 
establish that the Beneficiary acquired lpecial rowledge of the product. We note that some of the 
Beneficiary's! !training in was delivered by the named patent holders. However, 
he has continued to receive internal training froml !employees while assigned to the United 
States and the Petitioner has not claimed that such training is only available to employees who are 
physically present in France or those who have previously worked for the affiliate. 
We note the Petitioner explained that, in addition to thel I product knowledge, the Beneficiary's 
role as leads developer required specialized knowledge of the pharmaceutical market, the company's 
custom CRM (customer relationship management) system, and experience with third-party tools such 
as Linkedln Sales Navigator, IMS, and Medtrack software, which he used to assist with market 
research, to allocate qualified leads to account managers, and to manage customer data and profiles to 
support sales force prospection. The Petitioner did not further develop its claim as to how this 
combination of knowledge and skills qualify as specialized knowledge. The Beneficiary received two 
hours of training in "Microsoft Customer Relationship Management Software" and 90 minutes of 
Linkedln Sales Solutions training while employed abroad, but it appears that he was expected to 
acquire knowledge of the Petitioner's industry and knowledge of the company's internal sales 
qualification systems while on the job and did not receive formal training in these areas. 
Finally, the Petitioner states that the Beneficiary "as a result of his specialized knowledge" had a 
significant positive impact on the organization. Specifically, the Petitioner notes that his work 
"significantly enhanced" the foreign entity's competitiveness, image, and financial position. In this 
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regard, the Petitioner states that the Beneficiary's "specialized knowledge in oun I product line 
generated more than €1 million during his period of time with [the foreign affiliate] as a Leads 
Developer." The Petitioner provides a separate letter identifying five sales that were completed by the 
foreign entity in 2016 and 2017 based on leads qualified by the Beneficiary during his period of 
employment abroad. The record shows the Beneficiary was given a €1 million target for "sales from 
qualified leads" for 2015 and that this goal was eventually met in 2017. The Petitioner does not explain 
how the Beneficiary's eventual accomplishment of the sales prospecting goal set for him is indicative 
of his special knowledge. 
In general, all employees can reasonably be considered "important" to a petitioner's enterprise. If an 
employee, particularly one who was specifically charged with generating sales, did not contribute to 
the overall economic success of an enterprise, there would be no rational economic reason to employ 
that person. While the Beneficiary may have filled a role beneficial to the foreign entity's financial 
position or competitiveness in the marketplace, this characteristic alone is not probative of his 
specialized knowledge. The Petitioner must, as a threshold matter, demonstrate that a beneficiary 
acquired knowledge of the company's products or processes that is special or advanced, and the 
Petitioner here has not met that burden. A beneficiary's contributions to a company's competitiveness 
or financial position cannot substitute for the required specialized knowledge. 
Again, the Petitioner must establish that the position of leads developer required the Beneficiary to 
have knowledge that is uncommon in the industry and knowledge that could not be readily transferred. 
Here, the evidence showed that the Beneficiary stepped into the role with no apparent background in 
the pharmaceutica1
1 
industr] and was able to meet and exceed his qualified leads targets despite having 
just 15.5 hours of product-focused training over a one-year period. The Petitioner has not 
established that the position was one which involved or required specialized knowledge of the 
company's products. 
Clearly, any company will require members of its sales organization to understand the company's 
products, so that the staff can identify potential customers and explain the advantages of the product. 
The knowledge that comes from sales experience, however, does not necessarily amount to specialized 
knowledge as the regulations define that term. We note that all employees can be said to possess 
unique skill sets to some degree; however, a skill set that can be easily imparted and mastered is not 
"special knowledge." The Petitioner has not shown that the Beneficiary, as a leads developer, acquired 
familiarity with its proprietary products that meets the threshold of special knowledge, or that he was 
employed abroad in a position requiring specialized knowledge. Rather, the Petitioner describes the 
position as a "supporting role" and presented evidence that the foreign entity was able to rely on 
temporary workers to fill vacancies for its leads developer positions. 
While there may not be any employees with the exact knowledge the Beneficiary possesses, the record 
does not support the Petitioner's claim that the Beneficiary's knowledge gained as a leads developer 
was in fact significantly different from that generally held by workers in similar positions in the 
industry, or by other similarly employed workers in the foreign entity. 
For the foregoing reasons, the record does not establish that the Beneficiary possesses special 
knowledge of the company's products and sales methods and their application in international markets. 
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C. Advanced Knowledge 
The Petitioner has not established, in the alternative, that the Beneficiary possesses advanced 
knowledge. We note that the Petitioner's primary claim relates to the Beneficiary's "special 
knowledge" of the company's product and this claim has been addressed above. Although the 
Petitioner also generally claims that the Beneficiary possesses advanced knowledge of the company's 
processes and procedures, it has not sufficiently articulated this claim by clearly identifying any 
specific processes or procedures or explaining when and how the Beneficiary was able to acquire 
advanced knowledge during his 14 months of employment abroad as a leads developer. Therefore, in 
the absence of any additional evidence or argument on appeal, we will not disturb the Director's 
determination that the Petitioner did not establish that the Beneficiary possesses advanced knowledge. 
Issues or claims that are not raised on appeal are deemed to be waived. See, e.g., Matter of M-A-S-, 24 
l&N Dec. 762, 767 n.2 (BIA 2009). See also Sepulveda v. U.S. Att'y Gen., 401 F.3d 1226, 1228 n. 2 
(11th Cir. 2005); Hristov v. Roark, No. 09-CV-27312011, 2011 WL 4711885 at *1, *9 (E.D.N.Y. 
Sept. 30, 2011) (the court determined the plaintiff's claims to be abandoned as he failed to raise them 
on appeal to the AAO). 
D. Prior L-lB Approval 
Finally, we acknowledge that USCIS approved the initial L-lB petition that the Petitioner filed on 
behalf of the Beneficiary. Each petition filing is a separate proceeding with a separate record. In 
making a determination of statutory eligibility, USCIS is limited to the information contained in that 
individual record of proceedings. 8 C.F.R. § 103.2(b)(16)(ii). We are not required to approve 
applications or petitions where eligibility has not been demonstrated, merely because of prior 
approvals that may have been erroneous. See Matter of Church Scientology lnt'I, 19 l&N Dec. 593, 
597 (Comm'r 1988); see also Sussex Eng'g, Ltd. v. Montgomery, 825 F.2d 1084, 1090 (6th Cir. 1987). 
In addition, our authority over the USCIS service centers, the office adjudicating the nonimmigrant 
visa petition, is comparable to the relationship between a court of appeals and a district court. Even if 
a service center director has approved a nonimmigrant petition on behalf of an individual, we are not 
bound to follow that finding in the adjudication of another petition. See La. Philharmonic Orchestra 
v. INS, No. 98-2855, 2000 WL 282785, at *2 (E.D. La. 2000). 
IV.CORPORATE STATUS 
We note that routine checks of publicly available corporate records indicate that the Petitioner, a 
Delaware limited liability company (LLC) which had registered to do business as a foreign LLC in 
the State of Illinois, had its status "revoked" by the Illinois Secretary of State in July 2019, subsequent 
to the filing of this appeal. The record reflects that the Petitioner's headquarters (which is also the 
Beneficiary's worksite) are in Illinois. We were unable to verify whether the Petitioner remains in 
good standing in Delaware or in another state. 
The revocation of the Petitioner's active status in Illinois may be material to its eligibility for the 
requested visa. While we are not denying the petition on basis of this information, this issue should 
be addressed by the Petitioner in any future proceeding. Specifically, this revocation may indicate 
that the Petitioner does not continue to exist as an intending employer, that it is not authorized to 
9 
conduct business, and that it is no longer a qualifying organization. See section 214(c)(1) of the Act; 
see also 8 C.F.R. §§ 214.2(1)(1)(ii)(G) and (1)(3). 
V. CONCLUSION 
For the reasons discussed, the Petitioner has not established that the Beneficiary possesses specialized 
knowledge. Accordingly, the appeal will be dismissed. 
ORDER: The appeal is dismissed. 
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