Service detail

EB-1A petitions, drafted for both steps of the analysis USCIS actually runs.

Meeting three of the ten regulatory criteria is only step one. Kazarian v. USCIS established a second step — a final merits determination on sustained acclaim — that a petition can still fail even after clearing step one. Proximate drafts for both steps from the start.

What Proximate prepares

I-140 petition drafted against all ten regulatory criteria at 8 CFR 204.5(h)(3), plus comparable evidence where applicable
Evidence packaging that separates step-one criteria proof from step-two final-merits narrative
Exhibit review for the common weak points USCIS names directly: praise-only expert letters, employer-credited awards, and judging invitations without proof of completed review
Case summaries for attorney review before the file moves to final assembly

Best fit

Firms with a candidate who technically meets 3+ criteria but needs a sustained-acclaim narrative built around the record
Petitions previously denied at the final-merits stage after clearing step one
Cases needing comparable evidence arguments where standard criteria don't fit the occupation
Firms that want criteria-by-criteria evidence review before the file goes to the attorney

The question firms actually ask

Our candidate meets 3 of the 10 criteria on paper — is that enough?

It's enough to clear step one. It is not the same question as step two, the final merits determination, which asks whether the record as a whole shows sustained acclaim and a person at the very top of the field — and a petition can pass step one and still be denied there. Proximate drafts the narrative for both steps together, not just the criteria checklist.

Governing authority

Statute: INA 203(b)(1)(A)
Regulation: 8 CFR 204.5(h). The ten criteria are at 204.5(h)(3); comparable evidence is at 204.5(h)(4).
USCIS Policy Manual: USCIS Policy Manual, Volume 6, Part F, Chapter 2, plus the appendix “Extraordinary Ability Petitions, First Step of Reviewing Evidence”
Forms: Form I-140.
Controlling precedent: Kazarian v. USCIS, 596 F.3d 1115 (9th Cir. 2010) — established the two-step analysis.

What USCIS scrutinizes

Step one asks whether the evidence technically meets at least three of the ten criteria.
Step two, the final merits determination, asks whether the record as a whole shows sustained acclaim at the very top of the field — a petition can pass step one and still fail here.
Expert letters that use praise instead of specifics add no value, and USCIS says so directly.
Awards and memberships must belong to the person, not the employer. Published material must be about the person and their work, not their employer.
Judging requires proof the review was actually completed, not just an invitation to judge.

Turnaround for this case type

Internal production time -- drafting plus internal quality control, once a case is in production and the file is complete. The clock pauses only for documented missing client documents or pending attorney feedback, never for workload.

EB-1 (All)

9 business days

7 drafting & assembly · 2 internal QC

Built for review control, confidentiality, and firm-owned judgment.

Proximate supports preparation and operational clarity. Legal strategy, legal advice, filing decisions, and final attorney review remain with the responsible law firm.

Richmond, TX search footprint

Support for firms searching locally around Houston and nationally.

Proximate works with immigration law firms in Richmond, Sugar Land, Houston, and across the Texas Gulf Coast, and supports firms nationwide through the same remote workflow.

RichmondRosenbergSugar LandMissouri CityKatyHoustonPearlandCypressThe WoodlandsConroe

Discuss this service lane with Proximate.

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