MAY292020_06B2203Decided 2020-05-29I-140

A law firm's EB-1A petition for a data/SAP specialist was dismissed because the beneficiary met only two of the…

Dismissed Useful for: avoid these mistakes
EB-1AField: Advisory FSO SAP, data integration, business intelligence and analytics, SAP Technical Architect, big data
The outcome

This appeal was not successful at this stage

The AAO dismissed the appeal because the beneficiary satisfied only two of the required three evidentiary criteria (judging and scholarly articles), falling short of the minimum threshold. The additional criteria claimed on appeal — original contributions of major significance, leading/critical role, and high salary — were all found unsupported by the evidence.

2 / 3 criteria needed Need 1 more

1 more criterion would trigger a full merits review.

In plain English

The Nebraska Service Center denied the petition, and the AAO affirmed on appeal. The beneficiary, an SAP and data integration professional, satisfied the judging and scholarly articles criteria but fell short of the three-criteria minimum. Claims of an Amazon Best Seller book, low citation counts, and project-level reference letters were all found insufficient to demonstrate original contributions of major significance or a leading/critical role. The salary comparison failed because the petitioner used outdated wage data and did not properly identify the beneficiary's role for comparison purposes. The AAO also noted that reference letters lacking company letterhead had reduced credibility, and that website addresses submitted without screenshots were not acceptable evidence.

What worked & what failed

What worked: The beneficiary's peer review of journal papers satisfied the judging criterion, and authorship of scholarly articles in professional publications satisfied the scholarly articles criterion.

What failed: The Amazon Best Seller claim lacked corroborating sales data and had only one reader review. Reference letters for the leading/critical role criterion lacked company letterhead, omitted job titles, and described only project-level work. The salary comparison used outdated BLS data from 2012-2013 and failed to identify the correct comparison group for the beneficiary's specific role.

Takeaway: Petitioners should submit concrete, quantified evidence of field-wide impact rather than relying on rankings or letters without specifics — Amazon rankings need sales context, citation counts need field-level benchmarking, and reference letters must be on official letterhead, name the beneficiary's exact title, and explain organization-wide (not just project-level) significance. Always use current wage data and identify the precise occupational category for salary comparisons.

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

  • The beneficiary's peer review of journal papers satisfied the judging criterion, and authorship of scholarly articles in professional publications satisfied the scholarly articles criterion.

Evidence that wasn't enough alone

  • The Amazon Best Seller claim lacked corroborating sales data and had only one reader review
  • Reference letters for the leading/critical role criterion lacked company letterhead, omitted job titles, and described only project-level work
  • The salary comparison used outdated BLS data from 2012-2013 and failed to identify the correct comparison group for the beneficiary's specific role.
Find more EB-1A cases with similar evidence patterns →
What the evidence showed

Criterion-by-criterion breakdown

Judging the work of others

Met

Beneficiary reviewed papers for journals; both Director and AAO agreed this criterion was satisfied.

Original contributions of major significance

Not met

Amazon Best Seller claim lacked sales figures; only one review on Amazon; 199 reads unsubstantiated; citation counts (10, 8, 8) too low and not contextualized; support letters speculative and conclusory.

Authorship of scholarly articles

Met

Beneficiary authored scholarly articles in professional publications; both Director and AAO agreed this criterion was satisfied.

Leading or critical role for distinguished organizations

Not met

Reference letters lacked company letterhead, did not mention job titles, described project-level work rather than organization-wide leadership, and failed to show distinguished reputation of employers.

High salary or other significantly high remuneration

Not met

BLS wage data was from 2012/2013 and outdated; petitioner failed to identify beneficiary's exact position; glassdoor screenshots did not establish high salary relative to others in the specific field.

Evidence that persuaded the AAO

Peer-reviewed journal paper reviews establishing judging criterion

Authored scholarly articles in professional publications establishing scholarly articles criterion

Where the evidence fell short

Amazon Best Seller ranking screenshot without sales figures or context

Single Amazon review and '199 Reads' screenshot without field-impact analysis

Support letter praising the book as 'well-written' with only speculative future impact

Google Scholar citations of 10, 8, and 8 for individual articles without explanation of major significance

Reference letters lacking company letterhead for leading/critical role criterion

Reference letters that described project-level contributions without establishing organization-wide leadership

Outdated BLS wage data from Fall 2013 using 2012 figures for salary comparison

Glassdoor salary screenshots without establishing the beneficiary's specific role or proper comparison group

Website addresses submitted without screenshots or printed documentation

Officer errors the AAO found

The petitioner argued the Director improperly compared citation counts to leading scientists as part of the initial evidentiary threshold analysis rather than reserving that comparison for the final merits step; AAO agreed the comparison was misplaced but found citations still insufficient to meet the criterion.

How the case moved

Completed

I-140 filed

SAP/data integration specialist and technical architect working with big data and business intelligence systems

Completed

Director — Denied

Initial decision: Denied.

Completed

Appeal to the AAO

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

2020-05-29

AAO decision — Dismissed

The AAO dismissed the appeal because the beneficiary satisfied only two of the required three evidentiary criteria (judging and scholarly articles), falling short of the minimum threshold. The additional criteria claimed on appeal — original contributions of major significance, leading/critical role, and high salary — were all found unsupported by the evidence.

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)-(x)8 C.F.R. § 204.5(h)(3)(iv)8 C.F.R. § 204.5(h)(3)(v)8 C.F.R. § 204.5(h)(3)(vi)8 C.F.R. § 204.5(h)(3)(viii)8 C.F.R. § 204.5(h)(3)(ix)
Kazarian (2010)Establishes the two-step analysis for extraordinary ability petitions: initial evidentiary threshold followed by final merits determination.
Kazarian (2009)Publications and presentations alone are insufficient without evidence of major significance; letters repeating regulatory language without explaining influence are insufficient.
VisinscaiaUpheld denial where petitioner did not corroborate impact in the field as a whole for original contributions criterion.
1756, Inc.USCIS need not accept primarily conclusory statements.
Matter of HoPetitioner must resolve inconsistencies in the record with independent, objective evidence; unresolved inconsistencies may undermine reliability of other evidence.
Matter of PriceHigh salary must be evaluated relative to others in the same field; even major-league-level performance does not automatically meet the extraordinary ability standard.
SkokosSalary information for those performing lesser duties is not a proper comparison to others in the field.
GrimsonSalary comparisons must be to peers performing the same role in the field.
MuniSalary comparisons must be to peers performing the same role in the field.