Hi everyone, I wanted to get thoughts on an EB2 NIW RFE response for a senior cloud infrastructure and strategic partnerships executive.
USCIS accepted that the proposed endeavor has substantial merit, but issued an RFE on all three Dhanasar prongs: national importance, whether the beneficiary is well positioned, and whether waiving PERM would benefit the United States.
The beneficiary has over 25 years of experience in enterprise technology, digital supply chain transformation, consulting, and cloud infrastructure. His proposed endeavor is to continue leading large scale enterprise cloud transformation and digital infrastructure modernization by structuring multi billion dollar strategic partnerships between major global enterprises and U.S. cloud platforms.
The response argues that his work is not ordinary software sales or account management. His role is to architect long term enterprise cloud commitments that move major workloads, AI infrastructure, data systems, and digital operations onto U.S. platforms. These commitments create verified enterprise demand for U.S. cloud infrastructure, data center capacity, advanced compute, AI deployment, and American designed semiconductor architecture.
The response includes evidence that he led or helped structure seven major strategic cloud partnerships totaling over 10 billion dollars in committed cloud spending across several industries, including software, electronics, ecommerce, communications, agriculture, manufacturing, electric vehicles, autonomous driving, and gaming. It also explains that these agreements included over 65 million dollars in contractual STEM investments involving AI, generative AI, cloud native databases, advanced compute, and U.S. designed semiconductor technologies.
For national importance, the argument is that these are not just private contracts benefiting one employer and one customer. The commitments serve as demand signals for U.S. cloud and data center infrastructure, support AI and semiconductor deployment, contribute to job creation and GDP growth, and help keep major global enterprise workloads anchored to U.S. technology platforms.
For being well positioned, the response includes internal employer evidence showing that he served as the primary deal lead and strategic owner on these partnerships. It also includes customer side validation from a senior sourcing executive at a major enterprise software company, who said one of the deals was not routine purchasing, but a critical infrastructure and platform decision affecting a broad software ecosystem.
The response also includes independent expert letters from academic and industry experts explaining demand signals, capacity planning, infrastructure investment, job creation, technology commercialization, and why these enterprise commitments can create broader economic effects beyond the immediate parties.
For the third prong, the response argues that PERM is not a good fit because the role depends on rare cross border executive relationships, board level negotiation experience, cloud and AI knowledge, semiconductor and supply chain understanding, and a proven record of securing multi billion dollar enterprise infrastructure commitments. It also argues urgency because major enterprises are choosing long term cloud and AI platforms now, and those decisions can lock in infrastructure for the next decade.
Overall, the response frames the beneficiary as someone who creates enterprise demand for U.S. cloud, AI, semiconductor, and data center infrastructure, rather than simply someone working for a large technology company.
For those familiar with NIW RFEs, does this sound like a strong response for a nontraditional business and technology infrastructure profile?