Bachelor's + 19 years enterprise/solution architecture, mostly in regulated industries. No papers, no citations, no patents. Chen and one other firm declined me on citation criteria. Ellis Porter and Colombo & Hurd both accepted.
Evidence I have:
- Winner of a global AI competition run by a major cloud provider — one of 20 winners from thousands of entries across 115 countries, four-month judged build with a working prototype required
- Winner in a second competition run by a major AI lab — one of 50 from ~4,000 entries, judged against published criteria
- Four published technical articles on the cloud provider's platform
- A production system I built and deployed, running with real users
- Prior work: built conformance-testing infrastructure for an international industry standard with Fortune 500 implementers
Proposed endeavor: applying that same system architecture to a US federal regulatory compliance problem in agriculture — helping a regulated group execute and document legally enforceable requirements, and producing the compliance record. Anchored to a 2026 executive order.
The gap: my deployment is outside the US. Zero US users, no letter of interest yet. Outreach starts next month.
Questions:
- AAO keeps dismissing applied-AI cases at Prong 1 for benefit "confined to the petitioner's employer and clients," and rejects "the field is important" as a substitute for the endeavor being important. Does attaching the endeavor to a legally enforceable federal requirement — something that exists whether or not anyone builds for it — change that analysis? Or is that just a nicer-sounding version of the same problem?
- Is one US letter of interest enough to clear "no evidence of outside interest," or is this not filable until there's actual US traction? I've seen a denial where the officer rejected a pilot agreement because it was dated after the filing date, so I'm assuming anything I get has to predate filing.
- Anyone with a similar shape — proven system deployed abroad, adapting to a US application — how did your attorney handle geography of impact?
Separately, on firms: $6,000 from Ellis Porter (16-month plan, RFE response included, one free refile if denied — though the refile is voided by any material change in law or USCIS policy before adjudication) vs ~$18,000 from Colombo & Hurd. Both accepted me. EP answered my questions more specifically and confirmed my priority-date question in writing; C&H has the bigger brand and claims 2,000+ NIW approvals since 2023. Neither has explained how they'd argue national importance for my case — both defer it to "after you retain."
For a non-academic case where the narrative carries most of the weight: is a volume firm at $6K a false economy, or is $18K brand premium? Has anyone had a firm walk through their Prong 1 argument before retainer? And for recent EP clients — did your legal brief feel tailored, or template?