Approved after rebuilding the argument post-RFE
Background
Ms. L has worked for years at the intersection of pharmaceuticals and medical technology. She filed an NIW centered on AI in healthcare, with plans to build a large AI-driven healthcare platform.
Challenges
USCIS questioned whether her project was merely an extension of her current employer's business, with value limited to her employer or its clients. Even though she had already developed and sold an AI platform, USCIS still questioned the startup funding and scalability of her future project. The healthcare system pain points cited in her expert recommendation letters were also treated as "general social problems" that did not show she personally was irreplaceable.
Strategy
We shifted the focus from "creating value for an employer" to "addressing structural pain points in the U.S. healthcare system." We linked her past commercialization of an AI platform to her future healthcare AI system as one continuous line of capability, and added the facts that she had formed an independent entity and received expressions of interest from outside investors. We also rebuilt the argument for "why her" rather than relying on general expert praise.
Outcome
Approved less than 45 days after the RFE response was filed.
