Responding to an RFE on “Original Contributions of Major Significance”
Discussion One
A practical, evidence-driven discussion
One of the most misunderstood EB-1A criteria is original contributions of major significance. Many applicants believe that proving technical excellence or product development is enough. An RFE often clarifies that USCIS is asking a different question entirely.
Not what you built.
But why your work mattered to the field as a whole.
This discussion walks through how such an RFE can be addressed effectively, using a real-world response structure while redacting all critical and confidential information.1
The Core RFE Concern
In this case, USCIS acknowledged that the beneficiary had contributed original work in the field. However, the officer raised a familiar concern:
Developing products or services alone is not sufficient
The record must show major significance beyond routine job duties
The connection between the individual’s work and field-level impact must be clearly established
USCIS also reiterated that while expert letters are helpful, they cannot stand alone without independent, objective evidence demonstrating impact.
This aligns squarely with long-standing precedent and the Kazarian framework. Please read further to understand how to clarify.
Clarifying the Nature of the Contribution
A key point addressed in the response was classification clarity.
The beneficiary was not claiming scholarly contributions such as academic research or citation-based influence. Instead, the claim was explicitly framed as business-related original contributions, consistent with 8 CFR 204.5(h)(3)(v).
The response emphasized that:
The work involved designing and architecting large-scale enterprise platforms
Responsibility for initiatives of this magnitude is reserved for a small group of highly trusted senior leaders
The contributions shaped how organizations across regulated industries operate at scale
This framing matters. USCIS evaluates significance differently for business contributions than for academic ones.
Addressing USCIS’s Specific Objections
USCIS questioned whether the evidence demonstrated why the beneficiary’s work rose to the level of major significance.
To address this, the response did three things:
Reiterated previously submitted evidence, tying it more explicitly to field impact
Introduced new probative evidence that could not be shared earlier due to confidentiality
Mapped all evidence back to regulatory language, not job titles or internal praise
Importantly, the response explained that certain internal documents were withheld initially due to company policy and were now being submitted with employer authorization.
Establishing Major Significance Through Business Impact
The response focused on outcomes, not effort.
Key themes included:
Leadership of large-scale platform migrations affecting approximately one thousand enterprise customers
Direct correlation between these initiatives and increased adoption of next-generation platforms
Measurable business outcomes such as customer retention, expanded engagements, and revenue growth
Efficiency gains and cost optimization for customers operating in highly regulated environments
Rather than asserting significance, the response demonstrated it.
Sector-Wide Influence, Not Isolated Success
Another critical element was showing that the work did not benefit a single employer alone.
The response highlighted how the beneficiary’s contributions:
Impacted organizations across financial services and healthcare sectors
Enabled scalability, security, and compliance for institutions operating at national and international levels
Influenced how enterprise data platforms are adopted in hybrid and cloud environments
Client names and internal metrics were redacted or summarized where necessary, but the breadth and seriousness of impact were unmistakable.
Supporting Evidence Beyond Letters
The response deliberately avoided relying solely on testimonial letters.
Instead, it combined:
Employer-authorized internal communications
Redacted reports showing adoption and renewal trends
Case studies demonstrating operational and economic benefits
Industry publications and peer-reviewed materials authored by the beneficiary
Independent recognition through awards and external acknowledgment
Evidence of government and economic reliance on the underlying technologies
Letters were used as context, not as the cornerstone.
Why This Approach Works
USCIS does not ask whether an applicant is excellent at their job.
It asks whether their work moved the field forward.
This response succeeded because it:
Respected adjudication logic
Anchored claims in outcomes, not assertions
Addressed confidentiality transparently
Connected individual work to industry-wide consequences
Treated the RFE as a clarification request, not an accusation
Final Reflection
RFEs on original contributions are not about proving brilliance. They are about proving significance.
When framed correctly, business-related contributions can be just as compelling as scholarly ones. The difference lies in how clearly the story is told, how carefully the evidence is curated, and how well the response aligns with USCIS’s decision-making framework.
Clarity, not volume, is what ultimately moves a case forward.
This discussion is provided for general informational purposes only and reflects common evidentiary practices observed in employment-based immigrant petitions. It does not constitute legal advice. Petitioners should coordinate closely with their employer and qualified immigration counsel to ensure that any documents shared in response to an RFE comply with company confidentiality policies and are presented in alignment with applicable USCIS regulations and adjudicative standards.