MAR072022_02B2203Decided 2022-03-07I-140

A cleaning company CEO's EB-1A petition was dismissed after failing to satisfy any of the three required evidentiary…

Dismissed Useful for: avoid these mistakes
EB-1AField: commercial and residential cleaning service; entrepreneurship/business
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the petitioner failed to satisfy even three of the ten required evidentiary criteria. The evidence of awards, memberships, and published material all fell short of the regulatory requirements.

0 / 3 criteria needed Need 3 more

3 more criteria would trigger a full merits review.

In plain English

The petitioner, a CEO and owner of a commercial and residential cleaning service, filed an EB-1A extraordinary ability petition but could not satisfy even three of the ten required criteria. His only award was a student competition prize with six entrants at one university, which the AAO found was not nationally or internationally recognized for excellence. His Chamber of Commerce membership was open to any reputable applicant and did not require outstanding achievements judged by national/international experts. His media coverage either was not 'about' him, lacked required author attribution, or lacked circulation data showing major media status. Several potentially stronger pieces of evidence — including later awards, board membership, and more prominent media features — were disqualified because they occurred after the May 2019 petition filing date. Because the petitioner could not clear the three-criterion threshold, no final merits determination was conducted.

What worked & what failed

What failed: 1. Awards from student competitions limited to one institution are not 'nationally or internationally recognized' for excellence — they inherently exclude established professionals. 2. General-membership organizations like a local Chamber of Commerce do not satisfy the membership criterion because joining does not require outstanding achievements judged by recognized experts. 3. Articles must be both 'about' the petitioner and published in demonstrably major media; evidence of the latter requires comparative circulation data, and author attribution is mandatory.

Takeaway: Petitioners must carefully time their filing to include their strongest available evidence, since post-filing achievements cannot cure deficiencies. Before filing, they should build a record of national-scope awards with documented selection criteria, memberships in selective associations with expert-judged admission, and media coverage in publications with verified major circulation figures.

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

  • See summary above for details.

Evidence that wasn't enough alone

  • Awards from student competitions limited to one institution are not 'nationally or internationally recognized' for excellence — they inherently exclude established professionals
  • General-membership organizations like a local Chamber of Commerce do not satisfy the membership criterion because joining does not require outstanding achievements judged by recognized experts
  • Articles must be both 'about' the petitioner and published in demonstrably major media
  • evidence of the latter requires comparative circulation data, and author attribution is mandatory.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Lesser nationally or internationally recognized prizes or awards

Not met

The Entrepreneurial Spirit Award from a university championship with only six competing student teams was not nationally or internationally recognized for excellence in the field. Awards received in 2020 and 2021 were filed after the May 2019 petition date and not considered.

Membership in associations requiring outstanding achievement

Not met

Membership in the local Chamber of Commerce did not require outstanding achievements judged by recognized national or international experts; any reputable person or business could apply. Chamber Ambassador and board membership evidence was either insufficient or post-filing.

Published material about the person

Not met

Most articles were not about the petitioner or lacked required author attribution. The two qualifying articles lacked comparative circulation data to establish major media status. Post-filing materials from 2020-2021 were not considered.

Evidence that persuaded the AAO

Two articles about the petitioner: a March 2019 Daily Leader article about his background and cleaning services business, and a February 2018 Chamber Connection interview about his personal philosophy and membership benefits — accepted as being 'about' the petitioner but insufficient to establish major media status

Where the evidence fell short

2014 university Entrepreneurial Spirit Award — limited to student competitors at one institution, not nationally or internationally recognized for excellence

Chamber of Commerce membership — open to any reputable person or business; does not require outstanding achievements judged by national/international experts

lastartupprize.com article — about the competition, not about the petitioner

The Tech Talk article — described the petitioner's description of something, not published material about the petitioner

Chamber Connection ribbon-cutting listing — lacked author attribution, a regulatory requirement

Unpublished article authored by the petitioner — no proof of publication

Young Business Leader of the Year award (January 2020) — received after the May 2019 petition filing date

Certificate of Recognition (June 2021) — received after the May 2019 petition filing date

2020 Life Magazine article and myarklamiss.com video — post-filing date

2021 Life Magazine advertisement — post-filing date

Board of directors appointment (October 2019) — occurred after May 2019 filing date

Daily Leader and Chamber Connection articles — no comparative circulation data submitted to establish major media status; Chamber Connection article also lacked author attribution

How the case moved

Completed

I-140 filed

Chief executive officer and owner of a commercial and residential cleaning service

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2022-03-07

AAO decision — Dismissed

The AAO dismissed the appeal because the petitioner failed to satisfy even three of the ten required evidentiary criteria. The evidence of awards, memberships, and published material all fell short of the regulatory requirements.

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.

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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)8 C.F.R. § 204.5(h)(3)(ii)8 C.F.R. § 204.5(h)(3)(iii)8 C.F.R. § 204.5(h)(3)(iv)8 C.F.R. § 204.5(h)(3)(viii)8 C.F.R. § 103.2(b)(1)8 C.F.R. § 103.3(b)
KazarianEstablishes the two-step framework for EB-1A adjudication: first assess whether initial evidentiary criteria are met, then conduct a final merits determination of sustained national or international acclaim
Negro-PlumpeArticles about a show or event are not 'about' the performer/petitioner for purposes of the published material criterion
Matter of PriceEven athletes performing at the major league level do not automatically meet the extraordinary ability standard
BagamasbadFederal agencies, like courts, are not required to make findings on issues unnecessary to the result they reach