JUN052024_01B2203Decided 2024-06-05I-140

The AAO dismissed an EB-1A appeal for a data scientist after reversing the Director's grant of the scholarly articles…

Dismissed Useful for: avoid these mistakes
EB-1AField: data scientist / information technology
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal after withdrawing the Director's finding that the petitioner satisfied the scholarly articles criterion, leaving her with only two of the required three criteria met. Without reaching the three-criterion threshold, the appeal was dismissed.

2 / 3 criteria needed Need 1 more

1 more criterion would trigger a full merits review.

In plain English

A data scientist filed an EB-1A extraordinary ability petition, claiming she met three criteria: published material, judging, and scholarly articles. The Director denied the petition at final merits but had found all three criteria satisfied. On appeal, the AAO reversed the Director's finding on the scholarly articles criterion, concluding that the petitioner's traffic data came from SiteWorth Traffic — an estimation tool relying on Alexa statistics that shut down in 2022 — and that screenshots pasted into a cover letter rather than actual printouts, combined with self-selected comparison websites, failed to demonstrate that Bitsight's blog or Towards Data Science qualify as professional or major trade publications. With only two criteria established instead of three, the AAO dismissed the appeal without conducting a final merits determination, though it noted in dicta that the record would also fail that step.

What worked & what failed

What worked: Two criteria — published material and judging — were found satisfied by the Director and were not challenged or disturbed by the AAO on appeal.

What failed: The scholarly articles criterion failed because the petitioner relied on SiteWorth Traffic, an unreliable estimation tool that uses a defunct analytics service (Alexa), submitted traffic data as screenshots pasted into a letter rather than proper exhibits, and compared her publications only to self-selected websites rather than providing an independent ranking of major trade publications in her field. Without this criterion, she could not meet the required minimum of three.

Takeaway: Petitioners relying on website or publication traffic data to establish 'major trade publication' status must use current, reputable, independently verifiable sources — not estimation tools of questionable accuracy — and should submit rankings of peer publications rather than cherry-picked comparisons. All evidence should be submitted as standalone printouts or official exhibits, not embedded screenshots in a cover letter.

For RFE responses & petition building

Cases like this are frequently used by attorneys when responding to RFEs or building initial petitions. The evidence patterns that worked (or failed) here directly reflect what USCIS officers look for when evaluating EB-1A criteria.

Evidence that moved the needle

  • Two criteria — published material and judging — were found satisfied by the Director and were not challenged or disturbed by the AAO on appeal.

Evidence that wasn't enough alone

  • The scholarly articles criterion failed because the petitioner relied on SiteWorth Traffic, an unreliable estimation tool that uses a defunct analytics service (Alexa), submitted traffic data as screenshots pasted into a letter rather than proper exhibits, and compared her publications only to self-selected websites rather than providing an independent ranking of major trade publications in her field
  • Without this criterion, she could not meet the required minimum of three.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Published material about the person

Met

Director found this criterion met; AAO did not disturb this finding.

Judging the work of others

Met

Director found this criterion met; AAO did not disturb this finding.

Authorship of scholarly articles

Reversed in their favor

Director granted criterion without analysis. AAO reversed, finding the evidence (SiteWorth Traffic data, screenshots pasted into letter, self-selected comparison websites) was inadequate and relied on a defunct Alexa-based service to establish that Bitsight and Towards Data Science qualify as professional or major trade publications.

Evidence that persuaded the AAO

Evidence supporting published material criterion (criterion iii) — accepted by Director and not disturbed by AAO.

Evidence supporting judging criterion (criterion iv) — accepted by Director and not disturbed by AAO.

Where the evidence fell short

SiteWorth Traffic website data: deemed unreliable because it uses custom algorithms, cannot guarantee accuracy, and continues to reference Alexa statistics, a service defunct since 2022.

Screenshots of SiteWorth Traffic data pasted into RFE response letter rather than submitted as actual evidentiary printouts.

Self-selected comparison websites used to show relative traffic of Bitsight and Towards Data Science, which may have excluded higher-traffic publications and thus did not constitute a proper ranking of major trade publications in the field.

Articles published on Bitsight's blog and Towards Data Science website: insufficient evidence that these qualify as professional or major trade publications due to inadequate traffic/readership data.

Officer errors the AAO found

Director granted the scholarly articles criterion (8 C.F.R. § 204.5(h)(3)(vi)) without providing any analysis or reasoning to support the finding.

Director relied on traffic data derived from SiteWorth Traffic, an estimation service that cannot guarantee accuracy and relies on Alexa statistics — a service defunct since 2022 — without assessing the reliability of that source.

How the case moved

Completed

I-140 filed

Data scientist who also founded an information technology company in the United States

Completed

Texas Service Center Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

Petitioner appealed to the Administrative Appeals Office for de novo review.

2024-06-05

AAO decision — Dismissed

The AAO dismissed the appeal after withdrawing the Director's finding that the petitioner satisfied the scholarly articles criterion, leaving her with only two of the required three criteria met. Without reaching the three-criterion threshold, the appeal was dismissed.

If you're appealing a similar decision, I-290B must be filed within 30 days of personal service of the denial, or 33 days if mailed.

Find this useful? A coffee helps keep Case Reviewer free and ad-free.

Buy me a coffee
Authorities the office relied on
8 C.F.R. § 204.5(h)(2)8 C.F.R. § 204.5(h)(3)8 C.F.R. § 204.5(h)(3)(i)-(x)8 C.F.R. § 204.5(h)(3)(vi)
ChawatheEstablishes that the petitioner bears the burden of proof and must demonstrate eligibility by a preponderance of the evidence.
Christo's Inc.AAO reviews questions de novo.
KazarianEstablishes the two-step framework: first count qualifying criteria, then conduct a final merits determination assessing sustained national or international acclaim.
AminFifth Circuit endorsement of the Kazarian two-part review framework.
Matter of PriceEven athletes performing at the major league level do not automatically meet the extraordinary ability standard, illustrating how restrictive the classification is.