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AAO concluded the proposed endeavor has substantial merit but the Petitioner did not show national importance. His skills and experience are second-prong considerations, and he did not document how his work would impact the SCM field broadly or generate substantial positive economic effects.

AAO agreed with the Director that while the endeavor has substantial merit, the Petitioner did not articulate or document how his legal analyst and business consulting activities would broadly impact his field. The reference letters addressed his contributions to specific employers and clients but did not demonstrate wider national implications. Without evidence of projected U.S. economic impact or job creation, the record did not show the proposed endeavor rises to national importance.

AAO withdrew the Director's national importance finding, concluding the Petitioner failed to sufficiently describe his proposed endeavor, did not distinguish research duties from engineering project duties, lacked evidence of research impact since leaving academia, failed to show how research findings would be publicly disseminated (vs. kept proprietary), and did not draw a sufficiently direct connection between his research and actual transportation improvements.

AAO found the recommendation letters overstated the impact of citations to the Petitioner's work and were not supported by the cited articles themselves, thus reducing their probative value. The Florida DOT funding was awarded to the university, not the Petitioner personally, and had no bearing on his current proposed endeavor. The Petitioner also failed to describe a sufficient plan for future activities. AAO agreed with the Director's conclusion that the Petitioner misapplied Matter of Katigbak, though AAO clarified the Director had not specifically identified rejected evidence.

The record shows only that SEGD membership is open to those in experiential graphic design or related fields, with no evidence of specific membership requirements based on outstanding achievements or a judging process by recognized national or international experts. The Petitioner's argument that his outstanding project work served as the basis for SEGD membership fails because there is no evidence connecting those projects to the membership application review process.

Reference letters from academic supervisors and former employer CEOs describe noteworthy projects and cite some academic references, but do not establish that the Petitioner's work has impacted the broader field beyond individual projects. The record lacks documentary evidence (e.g., copies of citing articles) to substantiate assertions of major significance, and none of the letters demonstrate that his contributions influenced how others in the field do their work.

Major media articles (cnbc.com, nytimes.com) discuss projects the Petitioner contributed to but do not mention him by name or discuss his individual contribution. Profile pages on SEGD and commarts.com lack required identifying information (title, date, author). Other submitted materials are either about the installation or about the employer company rather than about the Petitioner.

The Petitioner submitted W-2s showing salaries over $117,000–$125,000 and compared them to the OOH mean salary for graphic designers ($68,690), but the graphic designer occupational code explicitly excludes web and digital interface designers, and evidence in the record suggests more appropriate occupational codes were available. The Petitioner failed to submit alternative salary comparison evidence (e.g., industry surveys, professional organization data) as suggested in the RFE, and provided no support other than his own assertion that graphic designer statistics were appropriate for comparison.

AAO found that the RFE response improperly introduced a materially different proposed endeavor (NASA-funded prototype research) instead of clarifying the original endeavor, constituting an impermissible material change. Even as to the original proposed endeavor, the Petitioner failed to demonstrate national or global implications within the field—merely extending personal research and advancing knowledge in a field does not establish national importance under Dhanasar.

AAO found that managing a consulting company and providing services to clients benefits those clients but does not establish broader implications—significant economic impact, substantial positive economic effects, or national-level employment—as contemplated by Dhanasar. The tax projections, indirect job figures, and trade-development assertions lacked sufficient detail and context to rise to the level of national importance.