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AAO declined to reach the third prong, concluding that SCOPS' flawed analysis of prongs one and two tainted its brief conclusions on prong three, and remanded for SCOPS to address prong three anew in light of AAO's findings on prongs one and two.

AAO found that SCOPS improperly evaluated each piece of evidence in isolation rather than in totality. Taken together, the Petitioner's collaborations attested to by faculty, his patent application, his record of published research cited by others, and his active role in developing the described technology establish he is well positioned.

AAO withdrew SCOPS' conclusion due to inadequate analysis—SCOPS did not evaluate advanced-degree eligibility at all and failed to analyze the exceptional-ability criteria or provide totality-of-evidence analysis. AAO reserves the issue because the NIW analysis is dispositive.

AAO agreed that the Petitioner failed to demonstrate national importance. The Petitioner's arguments improperly focused on the importance of the field rather than the specific proposed endeavor, assertions about scalability and replicability were not supported by evidence, the support letters addressed only internal organizational impact, and the expert opinion letter had limited probative value because its author lacked relevant expertise.

AAO agreed with SCOPS that while the proposed endeavor has substantial merit, the Petitioner failed to demonstrate national importance. The record showed reliance on the general importance of AI rather than the specific prospective impact of the Petitioner's proposed research, recommendation letters did not address the specific proposed endeavor, evidence of employment activities did not establish broader field impact, and the Petitioner provided insufficient detail on how his research projects would generate national or global implications.

AAO withdrew SCOPS' finding, concluding that while the Petitioner holds a STEM Ph.D. (a positive factor), his citation record, publications, and support letters were insufficient alone to show he is well positioned. AAO found the Petitioner failed to adequately explain how he would independently carry out his research apart from his employment, did not sufficiently document his role in securing research funding or whether he was the primary investigator, and did not show his work had been adopted or influenced the field beyond being cited.

AAO found the Petitioner's claimed national importance rested on the value of her field rather than the specific prospective impact of her proposed endeavor. The record lacked sufficient detail about her lifecycle management system, failed to corroborate key quantitative claims, and the support letters and expert opinion were too conclusory to establish how the endeavor would produce broader, nationally important implications.

AAO acknowledges Petitioner's education, skills, and record of success as positive factors but concludes the record fails to establish a credible plan or progress toward the endeavor through his employment, and lacks evidence of interest from potential customers, users, investors, or other relevant entities. The supporting letter from his manager lacked letterhead and contact information, and recommendation letters were primarily from collaborators and did not address the proposed endeavor.

AAO found that while the petitioner holds a Ph.D. and has a publication and citation record, these alone are insufficient. The record lacks evidence of independent research progress, a detailed plan for future activities, demonstrated impact beyond citations, or a clear role as a principal investigator in funded grants. The petitioner's proposed research also overlaps substantially with his employment duties.

AAO found that while the Petitioner's expert letters and industry documents were generally supportive, they did not offer sufficient, detailed, and concrete examples of how the Petitioner's endeavor has the potential for broad and measurable national implications beyond his employer and its clients. The Petitioner failed to demonstrate that his work is independent of his employer's objectives or extends beyond routine employment duties to achieve national importance.