u/Desperate-Safety-425

I received an RFE for an EB-2 NIW I-140 and wanted to understand how others have addressed similar concerns.

Background:

• Work in software engineering focused on data systems, modeling workflows, and backend infrastructure
• Involvement in large-scale data pipelines and analytics systems
• Some contributions to research-oriented platforms and publications
• Experience with peer review activities

RFE Summary:

Prong 1 – National Importance:

• USCIS acknowledged the general field is important
• However, they stated that my specific work does not demonstrate impact beyond my employer
• Impact was described as theoretical
• No evidence of broader adoption, policy relevance, or measurable national-level outcomes

Prong 2 – Well Positioned:

• USCIS acknowledged qualifications
• However, they indicated:
  • insufficient independent validation
  • lack of demonstrated influence or adoption
  • not enough evidence that contributions are essential or uniquely impactful

Prong 3 – On Balance:

• Concluded that a labor certification waiver is not justified
• No clear evidence of urgency or broader national benefit beyond normal employment

Context:
The initial submission included system descriptions, some technical documentation, publications, and recommendation letters, but it seems the main issue is the lack of clearly demonstrated impact beyond the employer and limited independent validation.

Questions:

1. How have others demonstrated “impact beyond employer” for engineering or infrastructure-focused work?
2. What kind of evidence has worked to establish national importance without direct government or policy involvement?
3. What differentiates a “strong” vs. “insufficient” expert letter in practice?
4. Any examples of how internal systems work can be framed to show broader implications?

Appreciate any insights from those who have gone through similar RFEs.