EB-1A I-140 2,179 cases analyzed

How to Respond to an EB-1A Extraordinary Ability RFE

Officers most often push back on judging, original-contribution, and leading-role evidence — and on the final merits step even after criteria are met.

Cases analyzed
2,179
AAO appeal decisions
Sustained
4%
appeal fully successful
Remanded
13%
error found, sent back
Dismissed
83%
appeal not successful
What triggers this RFE
  • Fewer than three of the ten regulatory criteria are convincingly established, or the claimed criteria are thinly supported.
  • Judging evidence describes refereeing or rule-enforcement rather than substantive evaluation of others' work.
  • “Original contributions of major significance” are supported by citation counts alone, without independent evidence the field changed because of the work.
  • Even after meeting three criteria, the final merits determination fails because the totality of evidence doesn't show sustained national or international acclaim.
How to structure your response
  • Match each piece of evidence explicitly to the regulatory language of the criterion it's meant to satisfy — don't make the officer infer the connection.
  • For judging, include letters that describe the evaluation criteria applied, not just that a review occurred.
  • For original contributions, pair citation data with independent commentary (media, adoption, follow-on work) that shows real-world impact.
  • Write a closing “totality of the evidence” narrative that argues final merits directly — don't assume meeting three criteria is automatically enough.
Evidence that actually persuaded the AAO
Evidence that wasn't enough alone

Dismissed · 2022 Company-level awards (Asia Pacific Leadership in Green Building Awards 2018, Platinum Certification from Indian Green Building Council, 2018 Architectural Design Award, International Architecture Awards 2015, Certificate of Honorable Mention from Re-Thinking the Future Sustainability Awards, Jury Commendation from Design and Architecture Award) — all received by the company or project, not the petitioner personally

Dismissed · 2020 Letters from five associates (spouse of Japan's prime minister, former CEO of a portfolio company, a startup founder/CEO, a VP of a U.S. investment firm, and a government office chief representative) — found to reflect personal praise from close collaborators rather than independent evidence of field-wide impact

Dismissed · 2025 Letter from head of department of labor statistics providing average salary data for 'Heads of services and departments in the field of financial activity and insurance' — rejected because it did not cover petitioner's actual occupation and provided only average (not top-tier comparative) salary data.

Dismissed · 2025 Computer printout of a Kazakhstani presidential 'gold quality' diploma awarded to petitioner's wholesale tea company — rejected because award was issued to the company, not the petitioner personally, and no evidence showed the petitioner was named in award announcements or appeared on a podium

Dismissed · 2024 Membership documentation for Boy Scouts of America, Nepal Mountaineering Association, Nepal National Mountain Guide Association, Leo Club, and US Nepal Climbers Association — no bylaws or official criteria showing membership requires outstanding achievements judged by recognized experts

Officer errors that got real cases remanded
Officer error the AAO identified2024

Director imposed a novel substantive requirement for the published material criterion (8 C.F.R. § 204.5(h)(3)(iii)) by requiring that material focus on the petitioner's accomplishments in the wider field, rather than simply being about the person relating to their work, which is not supported by the plain language of the regulation or USCIS policy.

Officer error the AAO identified2015

Petitioner argued director improperly discounted expert letters that used the word 'young' to describe petitioner; AAO partially agreed that three letters did not use the term to qualify his accomplishments, but found one letter explicitly compared him only to other young scientists, which does not demonstrate field-wide impact.

Officer error the AAO identified2024

The Director erroneously found the published material criterion (8 C.F.R. § 204.5(h)(3)(iii)) satisfied; the AAO reversed this finding because the Globee article lacked required date and author, and the NewsBreak.com article was likely promotional content on an open-source platform without demonstrated major media status.

Officer error the AAO identified2017

The Director erroneously found the petitioner met the leading or critical role criterion (viii); the AAO withdrew this finding because the petitioner's roles were supporting roles, her film role was not shown to be for an organization with a distinguished reputation, and her music video appearance was as an extra.

Officer error the AAO identified2020

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.

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See all 2,179 EB-1A cases →