📰 Media Publications (2) 2026: Practice, Mistakes and Technical Nuances

All EB-1A Criteria

Awards - Memberships - Media - Scholarly Articles - Judging - Original Contributions - High Salary - Critical Role - Final Merits

This is Part 2

In Part 1 — what counts as "major media", USCIS requirements, examples of evidence and international media. Here — practice: quantity, format, typical problems, RFE examples and technical nuances.

Criterion 3 — Published Material (Media) — Part 2

Related articles Awards Memberships Scholarly Articles Final Merits Petitioner
O-1 / EB-1 Media Criterion 3 RFE Publications

Contents

Detailed analysis

RFE Denial Database

Publications in Media: practice and technical nuances

Main article on the subject: All EB-1A criteria: 10 types of evidence

How many media publications are needed for O-1 and EB-1A?

1-2 = RFE risk. 3-5 = recommended. 7+ = quality matters more.

Quantity Assessment
1-2 Minimal, risky
3-5 Recommended
5-7 Strong criterion
7+ Excellent, but quality matters more

From practice

From 150+ approved cases in 2024: the average petitioner submits 4-5 publications. Cases with 1-2 articles receive RFEs 3 times more often than those with 4+. But 10+ low-quality publications are worse than 3-4 strong ones in recognized major media.

All publications only in 2024-25 — will that raise suspicion?

Short answer: For Plain Language — most likely counted. For Final Merits — may be devalued.

What to consider about media when thinking about Final Merits?

Realistic expectations:

If your publications are gathered over 1-2 years (not 3-5), the media criterion will most likely help only at the first stage (Plain Language). And that is already A LOT.

Two articles = “not sustained acclaim”

“You also submitted evidence that you have been featured in two online articles. However, you did not demonstrate that you have garnered wide attention from the field based on one article about your work as a manager. You have not established that you have enjoyed sustained national or international acclaim based on two articles.”

Two online articles do not demonstrate "sustained national or international acclaim."

Gap in publications = problem

“The record shows the petitioner wrote scholarly articles between the years 1998 to 2005, and then further wrote four scholarly articles in 2024. The petitioner has not demonstrated how a gap between the years 2005 to 2024, would demonstrate a level of sustained acclaim.”

A long gap between publications = "how does this demonstrate sustained acclaim?"

Articles did not show influence on the field

“The articles submitted as evidence of published material about the beneficiary in major media have not established the beneficiary as an individual who has risen to the top of his field of endeavor. The articles fail to show how the published material about the beneficiary’s work influenced the field or that the beneficiary has been able to sustain national or international acclaim.”

The officer wants to see: how did the publications influence the field? Mere presence of articles is not enough.

One article 2014 + one 2024 = not sustained

“The petitioner has not demonstrated that one article from 2014, and one article from 2024 meet a level of sustained acclaim and further demonstrates the petitioner is at the very top of the field.”

Even if the articles are 10 years apart — the large gap does not help. Regularity of publications is needed.

“Discussion about her work” ≠ top of field

“Though the published material about the petitioner indicates that there has been discussion about her and her work, it is insufficient to establish that the commentary signifies the petitioner has risen to the top percentage of the field and that she has demonstrated sustained acclaim.”

Even if there are publications about you and your work — that does not guarantee that you have "risen to the top." More evidence is required.

RFE example: criterion met, but denied on Final Merits

Rare case

“CRITERION MET initially, but failed in Final Merits Determination.”

The criterion passed the first stage (plain language), but failed at the second (Final Merits).

Officer wording

“The record shows that the petitioner and his work have been featured in Amazing Architecture, Design and Survey Construction Works, Stroitelnaya Gazeta, and Komsomolskaya Pravda in 2022, 2023, and 2024. However, the petitioner has not demonstrated that he has achieved or maintained sustained national or international acclaim since being featured in these publications.”

The officer says: publications from 2022-2024 exist, but where is evidence of "sustained acclaim"? Publications are a moment of recognition, not proof that it continues.

Practical takeaway:

  • Criterion ≠ visa approval
  • Final Merits evaluates the TOTALITY of evidence
  • A history of recognition is needed, not only recent publications
Examples of media devaluation on Final Merits because of dates

Articles from 2025 — counted, but devalued

“The petitioner has provided evidence of published material about the beneficiary in Tadvisor and CEO World in 2025. The evidence includes circulation data and the plain language criteria is met. As the evidence that meets the criteria is dated 2025, the record is insufficient to demonstrate that the beneficiary has sustained national or international acclaim.”

The officer explicitly says: "plain language criteria is met" (criterion counted), BUT "dated 2025" = "insufficient to demonstrate sustained acclaim."

5 articles over 4 years — “merely meets plain language”

“After a review of the record of proceeding with what appears to be five articles issued in 2021, 2022, 2023, 2024 and 2025; these five recent articles would not be considered evidence of extensive documentation of published material about you that elevates your contributions to major prominence with sustained national or international acclaim.”

5 articles over 4 years — formally pass, but DO NOT prove "sustained acclaim."

7 articles from 2022-2025 — do not reflect “very top”

“The record does not show that the petitioner’s authorship of approximately seven recent articles, published between 2022 through 2025, is reflective of the petitioner being among the small percentage at the very top of her field with sustained national or international acclaim.”

Even 7 articles over 3 years the officer calls "recent" and says they do not prove being in the "very top."

“Career of acclaimed work” — Congressional intent

“Relating to published materials, the beneficiary submitted articles published by various publications. However, the beneficiary did not establish that the publication of these articles is indicative of a ‘career of acclaimed work in the field’ as contemplated by Congress. The beneficiary has not shown that his overall press coverage is indicative of a level of success consistent with being among ‘that small percentage who have risen to the very top of the field of endeavor.’”

The officer cites Congress' intent: a "career of acclaimed work" is required, not just several recent publications.

Duplication of an article from one media outlet to another — how to present?

Indicate the original source. Reprints can be mentioned as additional evidence of distribution, but do not count as separate publications.

Problems and solutions

What to do if an article has no author?

  1. Check the page metadata
  2. Use the Wayback Machine
  3. Use “Staff Writer” / “Editorial Team”
  4. Attach a letter from the editorial office (if possible)
RFE example: no author = zero probative value

Officer criticism

“Several materials failed to identify the author of the material. As stated in 8 CFR 204.5(h)(3)(iii), the material must be printed in professional or major trade publications or other major media and such evidence ‘must include the title, date and author of the material, and any necessary translation.’ Since the materials failed to identify the author, they do not meet the regulation at 8 CFR 204.5(h)(3)(iii) and were given no probative value under this criterion.”

The officer says: the regulation requires title + date + author. Missing any one element = "no probative value" (zero probative value). The article simply is not counted.

Example with specific outlets

“A couple of materials (touch-magazine.eu, shoutoutla.com, and merlaine.net) failed to identify the author and/or the date of publication… Since these materials failed to identify the author and/or the date of publication, they do not meet the regulation at 8 CFR 204.5(h)(3)(iii) and were given no probative value under this criterion.”

Specific example: three outlets were rejected solely because author or date was not indicated. Article quality or outlet level does not matter without the formal requisites.

Articles without author + case law Lamilem Badasa

“It is noted that two of the articles provided did not attribute an author, therefore, have no probative value. Wikipedia, web portals, domains, blogs, social media: there are no assurances about the reliability of the content from these open, user-edited Internet sites. See Lamilem Badasa v. Michael Mukasey, 540 F.3d 909, 901-11 (8th Cir. 2008). Therefore, any documentation from Wikipedia, web portals or social media sites carry no evidentiary weight within the present proceedings.”

The officer combines two claims: (1) no author = no probative value, (2) web portals = no evidentiary weight. Lamilem Badasa case is a standard citation officers use to reject user-edited sites.

A letter from the editor DOES NOT replace the author in the article

“Submitted a letter from Alexey Maksimov, Editor-in-Chief at ITWeek, claiming the author of the article was Igor Bezruchkin… Further, the submission of letters from media sources, in order to identify who an author was for an article, is not sufficient. Evidence of authors must be identifiable on the article itself, in order for the article to be viable evidence.”

The officer says: you attached a letter from the editor naming the author — NOT accepted. The author must be identifiable IN THE ARTICLE ITSELF. A letter from the editorial office does not substitute.

Specific articles rejected for lack of requisites

“The F3fm.ru article, ‘Commercial Real Estate: Construction and Its Despots’ did not include the author’s name. Likewise, the article ‘National Demand’, did not include the date, and the record did not provide the publication. The inclusion of the title, date, and author of the material is not optional but a regulatory requirement.”

The officer emphasizes: title + date + author — this is a "regulatory requirement", not optional. An article can be perfect in content, but without these three elements it is not counted.

Stroygaz.ru and MSN — deficient due to missing requisites

“The pieces disseminated at stroygaz.ru and msn are deficient because they do not include the required title, date, author, or some combination of these. As stated in the regulation, material about the beneficiary must be published ‘in professional or major trade publications or other major media’ and ‘shall include the title, date, and author of the material.’ Thus, such documentation has no probative value for meeting this criterion.”

The officer rejected articles from Stroitelnaya Gazeta and MSN as "deficient" — insufficient. The word "shall" in the regulation indicates a mandatory requirement, not a suggestion.

Forbes, ZTB News, WEProject - specific denial examples
Court Precedent
"The article published in Forbes does not contain the date it was published. The article published in ZTB News does not specify an author. The article published in WEProject Media does not contain an author or date published. This information is required for all published media under this criterion."
Source: Forbes

Even Forbes was rejected for lacking a date! Forbes - no date, ZTB News - no author, WEProject Media - neither author nor date. Check every article for ALL three elements: title + date + author.

Kazakh articles without date - a concrete example

“The articles entitled: ‘Interview With Logistician [Name]: Green Smart Logistics Is The Key To The Future Of Transportation’ and ‘[Name]: The Inspiration of Eco-Smart Logistics for Kazakhstan’ do not appear to be labeled with the date on which they were published. As a result, this evidence cannot be considered probative.”

The officer rejected two Kazakh articles simply because the publication date was not indicated. Article content is irrelevant — without a date = "cannot be considered probative."

Film/media sites without author — specific examples

“We note that the articles from productionhost.com/blog and flickeringmyth.com do not meet the requirements listed at 8 CFR 204.5(h)(3)(iii) as no author is cited. We also note that a visit to the link for the article from kleo.ru suggests that the article does not exist.”

The officer checked the links! Two results: (1) productionhost.com/blog and flickeringmyth.com — no author, (2) kleo.ru — article "does not exist". Dead links = zero probative value.

The officer rejected: filmdaily.co, nofilmschool.com, flickeringmyth.com, ridus.ru — film/media sites; productionhost.com/blog — no author; kleo.ru — dead link

Officers check links!

Save articles to the Wayback Machine and attach PDFs/screenshots in case the site removes the material.

CRITICAL: USCIS checked links - found nothing! (Matter of Ho)

"USCIS searched on the World Wide Web for the links https://sm.news/trener-yulia-melnikova-razveala-mify-o-zanatiyakh-zhenshhin-pauerliftingom-71536, https://sm.news; https://interviewage.ru/post157189x12d1-zhenskiy-pauerlifting-sovremenniye-podkhod; https://www.similarweb.com/ru/website/sport-express.tu/#overview found in the various screen prints submitted by the self-petitioner and was not able to find any information online, as those links do not appear to be valid or exist online. This calls into question the validity and truthfulness of all the evidence submitted with the petition."

The officer PERSONALLY checked the links from screenshots and DID NOT FIND them! Note: sport-express.tu instead of .ru — possibly a typo in the petition, but the officer construed it as "calls into question validity and truthfulness of ALL evidence."

Doubt cast = reevaluation of ALL evidence (Matter of Ho)

"It is incumbent upon the self-petitioner to resolve any inconsistencies in the record by independent objective evidence. Doubt cast on any aspect of the self-petitioner's evidence may lead to a reevaluation of the reliability and sufficiency of the remaining evidence offered in support of the visa petition. See Matter of Ho, 19 I&N Dec. 582 (BIA 1988)."

Matter of Ho — doubt cast on ONE piece of evidence may lead to reconsideration of ALL evidence.

Matter of Namio + Ngan - disparagement = doubt on entirety

"Disparagement of some of the supporting evidence casts doubt upon the entirety of the record. Matter of Ho, 19 I&N Dec. 582 (Comm.1988). Matter of Namio, 14 I&N Dec. 412 (BIA 1973); Matter of Ngan, 10 I&N Dec. 725 (BIA 1964)."

Discrediting part of the evidence = doubt about the WHOLE case. Three precedents in a row — this is serious.

Check ALL links before filing!

  1. Open each link in incognito mode
  2. Check for typos in the URL (.tu instead of .ru)
  3. Save everything to the Wayback Machine
  4. Attach PDFs/screenshots in case the site goes down
  5. One broken link = doubt about the ENTIRE petition

Dzen.ru (Yandex.Zen) - no author = not considered

"Material under this criterion 'shall include the title, date, and author.' Articles from dzen.ru did not state an author and therefore were not considered."

The officer did not consider Dzen posts because no author was specified. Even if the article is high-quality and about you — without an author it "were not considered."

Problems with Yandex.Zen: many posts lack an author, the platform is user-generated content, and there is no editorial control.

What to do if links do not open for the officer?

  1. Attach a full screenshot with URL and date
  2. Save to the Wayback Machine
  3. Attach a PDF version
  4. Include the archived link in the petition

Full URL on each screenshot page helps

FROM RFE

"Evidence containing a full URL address on each page of screenshots, assists USCIS in determining the legitimacy of such evidence."

The officer explicitly indicates: a full URL on each screenshot page helps determine legitimacy of the evidence.

URL ≠ evidence. The officer will not go look for links

FROM RFE

"Counsel provided a URL address and directs USCIS to look outside the record for such evidence. However, the record itself must establish eligibility. The burden of proof in these proceedings rests solely with the petitioner. Section 291 of the INA, 8 U.S.C. § 1361."

You cannot simply give a link and expect the officer to find everything. EVERYTHING must be included in the petition as attached documents.

CRITICAL: USCIS checked links - found nothing! (Matter of Ho)

Quote from RFE

“USCIS searched on the World Wide Web for the links https://sm.news/…, https://interviewage.ru/… found in the various screen prints submitted by the self-petitioner and was not able to find any information online, as those links do not appear to be valid or exist online. This calls into question the validity and truthfulness of all the evidence submitted with the petition.”

The officer PERSONALLY checked the links from screenshots and DID NOT FIND them! The officer construed this as "calls into question validity and truthfulness of ALL evidence."

Matter of Ho — doubt cast = reevaluation of ALL evidence

“It is incumbent upon the self-petitioner to resolve any inconsistencies in the record by independent objective evidence. Doubt cast on any aspect of the self-petitioner’s evidence may lead to a reevaluation of the reliability and sufficiency of the remaining evidence offered in support of the visa petition. See Matter of Ho, 19 I&N Dec. 582 (BIA 1988).”

Matter of Ho — doubt cast on ONE piece of evidence may lead to reconsideration of ALL evidence.

Matter of Namio + Ngan - disparagement = doubt on entirety

“Disparagement of some of the supporting evidence casts doubt upon the entirety of the record. Matter of Ho, 19 I&N Dec. 582 (Comm.1988). Matter of Namio, 14 I&N Dec. 412 (BIA 1973); Matter of Ngan, 10 I&N Dec. 725 (BIA 1964).”

Discrediting part of the evidence = doubt about the WHOLE case. Three precedents in a row — serious.

Check ALL links before filing!

  1. Open each link in incognito mode
  2. Check for typos in the URL (.tu instead of .ru)
  3. Save everything to the Wayback Machine
  4. Attach PDFs/screenshots in case the site goes down
  5. One broken link = doubt about the ENTIRE petition

How to rebut the claim that articles are “recent” and written for the visa?

  • Show a publication history (not only the last year)
  • Explain the context (product launch, award, event)
  • Attach older publications even if weaker
  • Show that the media initiated contact

NEW: Self-solicited publications are under suspicion!

Officers have begun requesting evidence that a publication was NOT solicited by you:

FROM RFE

"No evidence was provided to show that the publications were not self-solicited in order to be published in the media."

What they may request:

  • Correspondence between the beneficiary and the media - correspondence with the editorial office
  • Evidence to show that the publication was by invitation - proof that the media initiated contact

Keep correspondence with journalists! An email from the editorial office inviting you to an interview — strong evidence.

All publications only in 2024-25 — will USCIS be suspicious?

Short answer: At the first stage (Plain Language) — likely counted. At the second stage (Final Merits) — may be devalued.

What are Plain Language and Final Merits?

USCIS examines petitions in two stages (this approach is set by Kazarian v. USCIS):

  1. Plain Language (Step 1) — a formal check: are there articles about you in media? Are title, date, and author indicated? Is there circulation data? If yes — the criterion is met.
  2. Final Merits (Step 2) — qualitative assessment: even counted criteria are evaluated for "sustained national or international acclaim" and "small percentage at the very top."

Subdomains (blogs.site.ru) — is that the same as the media outlet?

No. Officers distinguish:

Use only publications from the main domain.

Translations and languages

Translating media articles — is Google Translate acceptable?

No. USCIS requires:

  • Certified translation (the translator certifies accuracy)
  • A Certificate of Translation with signature
  • Not necessarily notarized, but certificate required

Google Translate may be used as a draft, then have it reviewed and properly certified.

Do translations need to be notarized?

Not required. Sufficient are:

  • Translator’s Certificate
  • Translator’s signature
  • A statement of translation accuracy

Notarization is optional, not a USCIS requirement.

Is an affidavit from the translator mandatory?

Yes, a translator’s certificate is required by law. The requirement is codified in 8 CFR 103.2(b)(3):

“Any document containing foreign language submitted to USCIS shall be accompanied by a full English language translation which the translator has certified as complete and accurate, and by the translator’s certification that he or she is competent to translate from the foreign language into English.”

What is NOT required:

  • Licensed translator
  • Notarial acknowledgment
  • Stamps or seals
  • A translation agency
Sample translator certificate

Full wording:

I, [NAME OF TRANSLATOR], certify that I am fluent in the English
and [ORIGINAL LANGUAGE] languages and competent in translating
from that language to English. I further certify that I have
translated the enclosed document entitled [TITLE OF THE DOCUMENT]
from [ORIGINAL LANGUAGE] to English and that the translation is
complete, true, and accurate to the best of my knowledge.

[SIGNATURE]
[DATE]
[CONTACT INFORMATION]

Short form:

I, [NAME], am competent to translate from Russian into English,
and certify that the translation of this document is true,
accurate and complete to the best of my abilities.

[SIGNATURE]
[DATE]
Can you translate documents yourself?

No direct prohibition, but risks exist.

In AAO practice there are decisions where self-translation lowered probative value of documents:

“…uncertified translations… were apparently translated by the petitioner, which lessens their probative value”

Practical conclusion: technically you can sign the certificate yourself, but it’s better to have a third party (friend, colleague fluent in both languages) sign. This removes the argument of bias.

Who should NOT sign:

  • You yourself (risk)
  • Family members (risk of bias)
Practical tips for translations

Translation quality matters more than the certificate:

  • USCIS officers do not read foreign languages
  • Translation must be in correct English without errors
  • Native English proofreading is recommended
  • Google Translate may be a draft, but final translation must be proofread

Format:

  • English translation must be attached to each original
  • Do not combine all translations into one document without originals
  • The translation structure must mirror the original

What can be shortened:

  • Not every document needs a full translation — you may translate key parts
  • Diacritical marks are optional

Video and audio:

  • Transcription in the original language is required
  • Plus an English translation of the transcript
  • Translator’s certificate for the translation
RFE example: no certified translation = denial

Quote from RFE

“The record did not included proper certified translations of the documents provided. Title 8 C.F.R. § 103.2(b)(3) holds that ‘[a]ny document containing foreign language submitted to USCIS shall be accompanied by a full English language translation which the translator has certified as complete and accurate, and by the translator’s certification that he or she is competent to translate from the foreign language into English.’ Because properly certified translations of the documents were not submitted, the evidence does not support the claims.”

The officer says: foreign-language documents WITHOUT certified translation = documents not considered.

One certificate for all documents is not accepted

“Furthermore, the submission of a single translation certification that does not specifically identify the document or documents it purportedly accompanies does not meet the requirements of the regulation at 8 C.F.R. § 103.2(b)(3).”

You cannot submit one general certificate for all translations. Each certificate must clearly identify which document it accompanies.

RFE example: highlight title, date, author in translations

Officer requirement

“To assist in determining that the published material contains the title, date, and author, please emphasize (highlight or underline, on the original and translated copy): The title, date, and author of the published material.”

The officer requires you to HIGHLIGHT or UNDERLINE the title, date and author both in the original and in the translation. Use a yellow marker or underline.

How to format a translation of a video interview?

  1. Create a transcript in the original language
  2. Translate the transcript into English
  3. Add a Certificate of Translation
  4. Attach screenshots from the video with timecodes

Article translated into other languages — is that a plus?

Yes, it shows international reach. Indicate:

  • Number of languages
  • Countries of distribution
  • Original source of the translation

Can you translate an article yourself?

Technically yes, but with risks. Anyone fluent can translate. However, if you sign the certificate yourself, AAO may reduce probative value due to potential bias.

Recommendation: have a third party (friend, colleague) sign the certificate.

Are publications in Russian sufficient for EB-1A?

Yes. Language does not affect the criterion. Important:

  • Translation into English
  • Evidence that the outlet is major in its country
  • Content is “about the alien” and “relating to the work”

International Media

Are Ukrainian media acceptable? How to prove major?

Yes, Ukrainian media are acceptable. To prove major status:

  • SimilarWeb data (ranking in Ukraine)
  • Compare with US analogues
  • Awards and recognition
  • Audience relative to the country population

Examples of strong Ukrainian outlets: Ukrainska Pravda, Liga.net, NV.ua.

Kazakh media — how to show significance?

Strategy for Kazakhstan:

  1. Show leadership in the country (top-10 by traffic)
  2. Compare audience to population (20M)
  3. Use Forbes Kazakhstan, Tengrinews as examples
  4. Attach rankings of Kazakh media

Belarusian media after 2020 — will USCIS accept?

USCIS does not make political distinctions. But note:

  • Many independent outlets have been closed or blocked
  • Use the Wayback Machine for archival data
  • State media may raise questions about independence

Publications in African/Indian media — count?

Yes, if you prove major status. For large markets:

  • India: Times of India, Economic Times — clearly major
  • Africa: show leadership in region/country

Key: country population + share of audience = major in context.

Outlet blocked in Russia — how to prove audience?

For outlets like Meduza:

  1. Data from before the block (Wayback)
  2. VPN traffic data (if available)
  3. Citations by Western media
  4. Awards (Meduza has international awards)

Russian-language outlet in the US — is it acceptable?

Depends on circulation and audience:

  • 20,000+ circulation — may qualify
  • Show reach among the Russian-speaking diaspora
  • Compare with other ethnic media in the US

Cost and buying publications

How much does a publication in a US media outlet cost?

Price range via PR agencies:

Media level Price
Niche trade outlets $500-1500
Mid-level (regional) $1500-3000
Major (Forbes, Inc, Entrepreneur) $3000-6000+

Prices depend on: format, volume, urgency, intermediary.

Is paying for a publication a violation?

No direct prohibition. But important:

  • The publication must pass editorial review
  • It must not be labeled “advertisement” or “sponsored”
  • The officer does not check payment, but checks quality

Can an officer find out the publication was paid for?

The officer does not investigate financial relations with media. The main issues:

  • Editorial control (not self-published)
  • No label “advertisement” or “sponsored”
  • High-quality content about your work

PR agencies that help with publications?

PR agencies help with:

  • Finding appropriate outlets
  • Writing the pitch/text
  • Communication with journalists
  • Arranging interviews

Important: ensure the result is editorial content, not advertorial.

Low-cost Russian outlets for interviews — which?

Budget options (up to 25,000 RUB):

  • Regional editions of federal networks
  • Industry portals
  • Mid-level online publications

Tip: better 2-3 strong outlets than 10 weak ones.

Should you disclose that a PR agency arranged the publication?

No. You do not need to state how the publication was obtained. Only the result matters: editorial article about you in major media.

Freshness and publication dates

Are old articles (2015) acceptable?

Yes, old articles can strengthen the case:

  • Show sustained recognition
  • Prove recognition was not “for the visa”
  • Important: provide archival data about the outlet for that period

Publications only in the last year — a problem?

May raise questions. The officer may think the articles were done for the visa. How to mitigate:

  • Explain context (recent achievement, product launch)
  • Show other evidence of long-term recognition
  • Add at least 1-2 older publications

Article without publication date — how to handle?

  1. Check page metadata (view source)
  2. Use Wayback Machine to determine a date
  3. Mark as “Published circa [year]” with explanation
  4. Attach Wayback screenshot with archive date

All publications in 2024-2025 — red flag?

Yes, this is a red flag for the officer. Recommendations:

  • Add context in the cover letter
  • Show reason (career growth, award, event)
  • Supplement with other criteria that have history
RFE example: interviews right before filing = promotional

Officer criticism

“Most of the articles are structured as interviews, and they were all published shortly before the petition was filed. While the articles are about the petitioner and his work in the field, they appear to be promotional articles.”

The officer noted: all interviews were published shortly before filing. This looks like preparation for the visa, not organic recognition.

Quote from the USCIS Policy Manual

“Marketing materials created for the purpose of selling the person’s products or promoting the person’s services are not generally considered to be published material about the person (this includes seemingly objective content about the person in major print publications that the person or the person’s employer paid for).”

Important: even "seemingly objective" content in major publications is not counted if it was paid for. Officers know PR exists.

4 outlets, only 1 recognized as major (others promotional)

“The petitioner submitted articles from Komsomolskaya Pravda (Belarus), Hackernoon, Cossa, and She Owns It. The evidence demonstrates that only Komsomolskaya Pravda qualifies as a professional or major trade publication or other major media. All of the articles are structured as interviews, and while they are all about the petitioner and her work in the field, they were published shortly before the petition was filed, and they appear to be promotional articles.”

Specific example: of 4 outlets only KP Belarus is recognized as major. Hackernoon, Cossa, She Owns It — rejected as promotional. Interviews shortly before filing = red flag.

Is publication 10 years ago a minus?

No, it is a plus. Old publications show:

  • Long-term recognition
  • Sustained success
  • Not “done for the visa”

Just provide archival data about the outlet.

Outlet closed after publication — how to prove?

  1. Wayback Machine — archived version of the article
  2. Articles about the outlet’s closure (often include stats)
  3. A Wikipedia page about the outlet (use only to find primary sources, do not submit Wikipedia itself)
  4. State: “At the time of publication, [outlet] was…”

Where to get statistics if the outlet closed?

  1. Wayback Machine — archived media kit
  2. Wikipedia — for locating primary sources (do not submit Wikipedia itself)
  3. Articles about the closure (often include stats)
  4. State: “At the time of publication…”

Video, podcasts and aggregators

Video interview on a media outlet’s YouTube channel — does it count?

Yes, if it is the outlet’s official channel:

  • Forbes Russia channel, RBC TV — count
  • Transcript + translation required
  • Attach channel data (subscribers, views)
RFE examples: video without transcript not considered

Transcript not provided

“Additionally, transcripts of the YouTube broadcasts were not submitted. Please submit transcripts of the YouTube broadcasts.”

The officer says: no transcript — no consideration. This is not a recommendation but a requirement.

Video not considered at all

“You also provided a web link to an online video interview in support of this criterion. The USCIS Policy Manual notes that qualifying media will include ‘professional or major audio or video coverage of the person and the person’s work.’ USCIS lacks any transcription of your cited video interview. As such, USCIS did not review this material in this proceeding.”

The officer plainly states: "USCIS did not review this material" — the video was NOT REVIEWED. Without a transcript the evidence is ignored.

Video without transcript ≠ “published material”

“In relation to the video works, you have not submitted evidence of a certified published transcript; therefore this would not be considered commensurate with the plain language of this criterion which indicates that this must be published material about the beneficiary.”

The officer explains legally: the criterion requires "published material." Video without transcript is NOT "published material" by definition. This is not nitpicking, but plain language of the regulation.

YouTube = “user-edited site”

“The petitioner submitted a screen capture from YouTube but there are no assurances about the reliability of the content from this open, user-edited Internet site where anyone can self-publish information. Further, it is not evident whether users come to the website intentionally or are redirected unintentionally, web traffic is not directly comparable to circulation.”

The officer says: YouTube is a site where anyone can post. There is no guarantee of reliability or objectivity. Also YouTube traffic cannot be equated to publication circulation — users may be redirected accidentally.

YouTube channel with 4 subscribers

“The petitioner provided a screen shot of a YouTube video… posted on the Communications bureau rupor agency YouTube channel. YouTube is a free, online video platform that enables individuals to upload their own videos and have their own channels. There is no assurance of reliability or objectivity from these sources that allow for self-created material to be posted. USCIS does not consider YouTube to be a professional or major trade publication or other major media without providing comparative data to show the media content can be considered ‘major.’ For instance, the record shows that there are four subscribers (as of November 5, 2024) and no indication of the number of verified views. Such a limited number of subscribers and no reference of the number of views would not appear to be major by any means.”

Specific example: a YouTube channel with 4 subscribers — the officer says "would not appear to be major by any means." For YouTube you need comparative data: many subscribers + many views.

Practical conclusion:

  • The officer will not watch your video
  • A full transcript in the original language is required
  • Plus a certified English translation
  • Plus proof that the channel/program is major media
  • YouTube alone is not considered major media
  • For YouTube you need: subscriber count + views + comparative data

Podcast from a major outlet — is it media?

Yes. Podcasts of NYT, Forbes, WSJ — an extension of their media. Format:

  1. Transcript of the episode
  2. Podcast metrics (rankings, downloads)
  3. Link to the parent publication

Guest appearance on a podcast — does it count?

Depends on the podcast:

  • Media podcast (Forbes, RBC) — yes
  • Independent podcast — need to prove major status (audience, ratings)
  • Personal blogger’s podcast — most likely no
RFE example: podcast without comparative data

Quote from RFE

“You provided evidence that the beneficiary was interviewed on a podcast, but you did not provide evidence about the podcast(s) regarding listeners/viewership and comparative data establishing the podcast(s) as ‘professional or major trade publications or other major media.’”

The officer requires for a podcast: (1) listener/viewership data, (2) comparative data — how the podcast ranks. Without that the podcast is not counted.

YouTube interview directly rejected

“You further provided a link to an interview on YouTube; podcasts, web portals, company websites, social media, and search engines are not subject to editorial review, are open to self-creation of material, and will not meet this criterion.”

A YouTube interview was directly rejected: "will not meet this criterion." Reason: no editorial review, open to self-creation.

News aggregators (Google News, Yandex News) — how to use?

Aggregators themselves are not media. But you can use them:

  • As proof that the article is indexed by major platforms
  • To show distribution reach
  • The primary source remains the original media

YouTube channel with 400K subscribers — is that media?

A complex case. A YouTube channel can be considered major media if:

  • Professional content (not vlogs)
  • Editorial process
  • Industry recognition
  • Regular audience

Better to use it as supplementary evidence, not main proof.

Radio appearance — does it count?

Yes, radio is media. Format:

  1. Transcript of the broadcast
  2. Radio audience data (Mediascope, Nielsen)
  3. Program information
  4. Recordings/screenshots if available

Video work posted on Instagram account with 400K followers — does it count?

No for this criterion. Instagram is a social network, not media:

  • No editorial control
  • Posting work ≠ article about you
RFE example: Instagram and YouTube explicitly rejected

Officer quote

“As an initial matter, social media posts that appear on apps such as Instagram and YouTube are insufficient under this criterion.”

The officer plainly states: posts on Instagram and YouTube are INSUFFICIENT for this criterion. Period. Follower count does not matter.

RFE example: YouTube channel Mir Belogorya - rankings do not prove major

Problem #1 — video removed

“The petitioner provided a YouTube link to the video interview, but upon accessing the link, an error message appeared stating that the video was removed.”

The officer checked the link — the video was removed. Always save copies!

Problem #2 — data only from the channel

“The petitioner provided material about the channel that posted the video, Mir Belogorya, but the evidence is only from its channel and the petitioner did not submit any objective, documentary evidence which demonstrates that it qualifies as professional or major trade publication or other major media.”

Data from the channel itself = self-serving. Objective evidence of major status is required.

Problem #3 — rankings do not prove major

“The petitioner submitted additional material which ranks the Mir Belogorya channel among other YouTube channels, and material which ranks the channel and websites with other news and media websites in Russia. However, these rankings do not demonstrate that any of the material qualifies as major media.”

Even rankings among YouTube channels and Russian media didn’t convince the officer. "Rankings do not demonstrate major media" — ranking by itself is not proof.

What counts as an article about you

Several articles in one outlet — is that one source?

Technically yes, but you can present it as:

  • Multiple publications = sustained interest from the outlet
  • Indicate each article separately
  • Do not overstate: “publications in Forbes Russia (3 articles)”

Interview with a group of people where you are one of five — does it count?

Weak evidence. The criterion requires “about the alien.” If you are one of five:

  • Show that your portion is substantial
  • Highlight quotes about you
  • Use it as supplementary evidence

Article about a startup where you are CEO — is it about you?

Depends on content:

  • Your name in the headline/lede — yes
  • Quotes from you and description of your role — yes
  • Only company name without you — no

Key: “about the alien”, not about the company.

Mention in a “Top 30 under 30” list — is that an article about you?

Yes, this is strong evidence:

  • Editorial selection
  • Recognition by major media
  • About you personally

Even a short description in a list counts.

Expert ranking/list in media — acceptable?

Yes, if:

  • Ranking appears in major media
  • Editorial selection (not paid)
  • There is a description of your expertise

Examples: “Top 50 Marketers”, “Most Influential in Tech”.

Expert comment in an article — is that about you?

Weak evidence. An expert comment:

  • The article is not about you, but about a topic
  • You are one of the sources
  • Better used for Final Merits
RFE example: expert comment ≠ article about you

Quote from RFE

“The petitioner provided few published articles that interviewed the petitioner expressing her opinion about the dairy industry in general and does not discuss her work in the field of Dairy Manufacturing Technology. As such, the submitted evidence does not meet this criterion.”

The officer says: you were interviewed and gave your opinion about the industry — but the article does not discuss YOUR WORK. Expert commentary on the industry ≠ coverage of your achievements.

Counts Does not count
Article about your projects and achievements Your opinion about the industry in general
Focus on your work You as a source for the topic
“John Smith revolutionized…” “Expert John Smith says the industry…”
RFE example: mentioning ≠ substantial discussion

Mentioning and quoting is insufficient

“Counsel states that ‘the articles explicitly mention the petitioner, the Managing Partner and General Director of GPGroup, and include his expert opinions on various industry-related topics.’ The Policy Manual states that ‘the person and the person’s work need not be the only subject of the material; published material that covers a broader topic but includes a substantial discussion of the person’s work in the field…’ Therefore, mentioning and quoting the petitioner do not establish that the articles include a substantial discussion of the petitioner and his work.”

The officer says plainly: "mentioning and quoting" ≠ "substantial discussion."

Two quotes = NOT substantial discussion

“The information about the petitioner provided in the report is as follows: ‘[Name] underscored the importance of established building codes and engineering systems, such as ventilation and lighting, in ensuring a healthy office environment. He advised against unnecessary changes to engineering systems…’ The petitioner has not demonstrated that two sentences attributed to the petitioner constitute a ‘substantial discussion’.”

The officer literally counts sentences: two sentences with your quote — NOT a substantial discussion.

12 articles, only 1 recognized as substantial discussion

“The petitioner provided examples of articles that mention the company, his name, or quote the petitioner. This is not evidence that the published works included a substantial discussion about the petitioner and his work. Additionally, articles that discuss projects completed by the petitioner’s work but do not refer to the petitioner in connection with the projects do not meet the criterion requirements. The Bfm.ru article, ‘Commercial Real Estate: Construction and Its Despots’ includes a discussion about the petitioner and his work.”

Real example: of 12 articles only ONE (Bfm.ru) was recognized as substantial discussion.

Quotes show respect, but not extraordinary ability

“The majority of the articles were not about the petitioner and her work, rather they included a quote made by the petitioner regarding the subject matter of the articles. While this indicates the petitioner’s opinion is respected, it does not establish extraordinary ability in the field.”

Interesting phrasing: the officer recognizes that quoting shows respect for your opinion, but this is not sufficient to prove extraordinary ability.

“About your work, but about you” — subtle distinction

“The submitted articles were primarily about your work. The articles mention your name or include your opinion, but published material must not simply be about your work, but about you - though it may not be unrelated to your work.”

Important clarification: an article about YOUR WORK ≠ an article ABOUT YOU. The article must be ABOUT YOU, even if related to your work.

“Content rather than publisher” — even major media will not save weak content

“At issue is the articles content rather than the publisher. In this instant case, the articles discuss the broad field rather than the petitioner.”

Critical point: even if publication is RBC, Forbes Russia, Meduza — that is not a guarantee. The officer looks at ARTICLE CONTENT, not the outlet.

Articles about industry with your quote — NUR.KZ example

“The articles from NUR.KZ titled ‘Can Kazakhstanis Find Out About the Income of Civil Servants and the President?’; ‘How Denunciations Help Fight Tax Evaders in the US and Kazakhstan’; and ‘Why Businesses and Citizens Do Not Want to Pay Taxes in Kazakhstan, Expert Says’ are not about the petitioner and his work in the field. Material only cites, quotes, references, or includes a photograph of the petitioner does not meet all the plain language elements of this criterion.”

Specific example: articles on taxes in Kazakhstan where the petitioner is an expert quoted — the officer: articles are about taxation, not about YOU.

“Merely quote you” — full formulation

“It is noted that several articles merely quote you, include a paragraph with your name, or simply discuss the events. However, there are no indications that your accomplishments are the focal point of these articles. Published material about the alien and their work in the field that include a substantial discussion of their work accomplishments may satisfy the plain language of this criterion.”

The officer lists what DOES NOT count: (1) mere quotation, (2) a paragraph with your name, (3) event coverage. The requirement: "your accomplishments should be the focal point."

Article about an event where you were a speaker — does it count?

Depends on focus:

  • Article focused on your presentation — yes
  • Article about the event that mentions you — weak
  • Just your name listed among speakers — no
RFE example: event articles not counted

Officer template text

“The evidence does not indicate that the published material was material that related to the beneficiary and the beneficiary’s work in the field. The majority of the articles submitted are event recaps and are not about the petitioner or her work. Media that simply recaps a competitive event is not about the petitioner, but rather is about the event itself.”

The officer says: a recap of an event is about the event, not about you. Even if you are mentioned.

Clarification #1 — about the employer

“The published material should be about the beneficiary’s work in the field, not just about the beneficiary’s employer or other organizations the beneficiary is associated with.”

An article about your company or organization — not an article about you personally.

Clarification #2 — substantial discussion

“Published material could cover another topic but should include a substantial discussion of the beneficiary’s work in the field.”

"Substantial discussion" — the key word. A passing mention does not suffice.

Clarification #3 — marketing materials

“Marketing materials created for the purpose of selling the beneficiary’s products or promoting the beneficiary’s services are not generally considered to be published material about the beneficiary.”

Advertising material, even if it looks like an article — not counted.

Clarification #4 — listings and footnotes

“Unevaluated listings in a subject matter index or footnote, or reference to the beneficiary’s work without evaluation are insufficient.”

Inclusion in a list or footnote is insufficient. There must be evaluation of your work.

An announcement of your talk in the media — is that published material?

Weak evidence. An announcement:

  • Is about the event, not your work
  • Lacks in-depth coverage
  • Use it as supplemental evidence

Article about a company with your quote — how to format?

If your name is mentioned and you are quoted as a leader/expert:

  • Highlight parts about you
  • Show your role in context
  • Explain the connection in the cover letter

Be careful: a quote ≠ an article about you.

Articles about the company without mentioning you by name — do they count?

No. The criterion requires “about the alien.” An article only about the company does not qualify.

Article without your name — only about the product/company?

Not acceptable for the media criterion about you. The requirement: “about the alien.” Without a name — no evidence that it is about you.

RFE example: article without name + case law

Quote from RFE

“The material from obozrevatel.com made no mention of you within the material nor did it discuss your work in the field. The USCIS Policy Manual notes that probative published materials should include a ‘substantial discussion of the person’s work in the field and mentions the person in connection to the work may be considered material about the person relating to the person’s work.’”

Officer position

“An article cannot be about someone if it does not find it necessary to even identify them, let alone discuss them in a meaningful way.”

The officer explains: if the author of the article did not find it necessary to name you — the article is not about you.

Case law — precedents

“It must be noted that articles that are not about the alien do not meet this regulatory criterion. See Noroozi v. Napolitano, 905 F.Supp.2d 535, 545 (S.D.N.Y. 2012); Negro-Plumpe v. Okin, 2:07-CV-820-ECR-RJJ at *1, *7 (D. Nev. Sept. 8, 2008) (upholding a finding that articles about a show are not about the actor).”

Two court precedents: courts confirmed that articles about a show are not articles about the actor.

Mussarova v. Garland, (2022) - recent precedent
Court Precedent
"Coverage that is about a broader topic in which the Petitioner is merely mentioned does not demonstrate that the published material itself is 'about the alien' and 'relating to the alien's work in the field' as the regulation mandates. See Mussarova v. Garland, 562 F. Supp. 3d 837, 848-49 (C.D. Cal. 2022) (finding the published material criterion's requirements are not satisfied where the articles are about events in which a foreign national was associated but were not about them)."

Mussarova v. Garland (2022) — the most recent precedent. The court confirmed: articles about events with which a person was associated — are NOT articles about that person.

“Briefly cites, quotes, references, photograph” — NOT substantial discussion

“A review of the material appears to establish the contents briefly cites, quotes, references, or includes a photograph of the petitioner. There is no discussion of the petitioner and his/her work in the field.”

The officer lists what DOES NOT work: brief citation, quote, reference, photo. All these are not "discussion of the petitioner and work."

“Only one or two sentences” — NOT primarily about you

“It is noted that each of the articles were not primarily about the petitioner and included only one or two sentences or brief references. The plain language of this regulatory criterion requires that the published material be ‘about the alien’.”

The officer says: if an article contains only 1-2 sentences about you — it is NOT an article "about the alien." The criterion requires that the published material be PRIMARILY about you.

Photographer: your photos in an article ≠ article about YOU

“In addition, some articles are not substantially about the petitioner. Rather, they are instead using the photos that were taken by the petitioner for the articles. As a result, they cannot be considered probative.”

Important for photographers: if an outlet uses YOUR PHOTOS in articles, that is NOT an article about you. The article illustrates YOUR WORK ≠ an article about your career.

Authored articles by the petitioner = self-manufactured evidence

“Lastly, the petitioner has submitted articles of which he is the author. However, self-manufactured evidence is not objective or probative documentary forms of evidence.”

The officer says: articles YOU authored are "self-manufactured evidence." Lack of objectivity = low probative value. The criterion requires other people writing about you.

Commentary without documentary evidence (Matter of Obaigbena)

“Counsel’s assertions cannot be seen as evidence because it comprises attorney statements and does not comprise documentary forms of evidence. See Matter of Obaigbena, 19 I&N Dec. 533, 534 (BIA 1988) (stating that counsel’s assertions ‘cannot serve as evidence in an immigration proceeding’). Furthermore, USCIS ‘need not accept primarily conclusory assertions.’ 1756, Inc. v. U.S. Attorney General, 745 F. Supp. 9, 15 (D.D.C. 1990). Furthermore, unsupported assertions do not meet the petitioner’s burden of proof. Matter of Soffici, 22 I&N Dec. 158, 165 (Assoc. Comm’r 1998).”

Three precedents in a row: unsupported assertions ≠ evidence. Attorney comments without documentary support do not meet the burden of proof.

RFE example: detailed list of what is NOT 'about you'

Officer’s full list of exclusions

“Published material cannot just be about the beneficiary’s employer or other organizations that the beneficiary is associated with, such as found in search engine optimization marketing materials, press releases or copy rewritten from press releases. General materials created for the purpose of selling or reviewing the beneficiary’s or the beneficiary’s employer’s products, providing general education, biographical information or project updates about the beneficiary’s field such as found in on-line business platform blogs and organizational newsletters, gameplay or player statistics, promoting the services, or updates on company restructurings or academic or private company research announcements are not generally considered to be substantial published material about the beneficiary.”

Does NOT count:

  • SEO content and marketing texts
  • Press releases and copy-pasted press release texts
  • Product reviews of the employer
  • General educational materials
  • Biographical information
  • Project updates
  • Blogs on business platforms
  • Organizational newsletters
  • Gameplay or player statistics
  • Advertising materials for services
  • News about company restructurings
  • Announcements of research

Argumenti Nedeli / Akkuyu NPP — article about employer

“You provided evidence from Argumenti Nedeli Newspaper and/or online source argumenti.ru; however, the evidence appears to be about Akkuyu NPP, rather than related to your specific work in the field. USCIS Policy Manual: Volume 6, Part F, Chapter 2 expresses that the published material should be about the person, relating to the person’s work in the field, and not just about the person’s employer and the employer’s work or about another organization and that organization’s work.”

Specific example: an article in Argumenti Nedeli about the Akkuyu NPP (a Turkish project of Rosatom) — the officer says it is about the PROJECT, not about the petitioner. Working on a famous project ≠ an article about you.

Detailed analysis

O-1 Petitioner: agency scheme

Article in KP about another outlet — does not prove major

“You provided information from kp.ru about Argumenti Nedeli; however, the evidence does not verify the circulation, readership, or viewership (for major trade publications and other major media) of the published material (compared) to other statistics.”

The officer rejected KP's article about Argumenti Nedeli as proof of the latter’s major status. Even being mentioned in a large outlet (KP) does not substitute for comparative circulation data.

Officer conclusion about "recent" articles

"After a review of the record with what appears to be five articles issued in 2021, 2022, 2023, 2024 and 2025; these five recent articles would not be considered evidence of extensive documentation of published material about you that elevates your contributions to major prominence with sustained national or international acclaim."

5 articles over 4 years — not "extensive documentation" and do not prove "sustained acclaim."

Editorial vs paid content

How to tell if content is editorial?

Signs of editorial content:

  • No labels “Sponsored”, “Partner”, “Advertorial”
  • Author is a staff journalist
  • Editorial style and critical perspective
  • Not published in an “advertisement” or “partners” section

Article in “Opinion” or “Blogs” section — does it count?

Depends on the section:

  • “Expert opinions” with editorial selection — may count
  • Open contributor platforms (e.g., Forbes Contributors) — do not count
  • Check the section’s policy
RFE examples: blog requirements

Three required conditions for blogs

“The article entitled: ‘Food photographer Artyom Zolotarev: Artistic taste and watchfulness help me navigate any shooting’ appears from blog. However, blogs are self-promotional info, lacking independence. Publications must be independent, have a national audience, and a board of editors.”

The officer listed three criteria for blogs: (1) Independence, (2) National audience, (3) Board of editors. Without all three elements the blog is NOT considered major media.

Reiteration in another RFE

“Moreover, blogs are self-promotional info, lacking independence. Publications for the purpose of this visa should be independent, reach a national audience, and have a board of editors.”

The officer confirms: for visa purposes the publication should be Independent, have a National audience, and a Board of editors. Most blogs do not meet these requirements.

Sponsored content vs native advertising — difference for USCIS?

For USCIS there is no difference — both are not acceptable:

  • Sponsored content — explicitly labeled “advertisement”
  • Native advertising — ad in the form of an article

Any label indicating paid placement = not counted.

Article based on a press release — is it editorial?

Depends on processing:

  • Journalist rewrote and added context — yes
  • Copy-paste of press release — no
  • Check whether the article has independent reporting

Article written by AI and edited by an editor — ok?

USCIS does not care how an article was written. Important:

  • Published in major media
  • Passed editorial control
  • About you and your work

OR advertising markings in Russian media — an issue?

An OR/erid marking (advertisement by law) = a problem:

  • Shows the content was paid
  • The officer may notice it during review
  • Better to avoid such publications

Wikipedia and web portals

Is Wikipedia acceptable under the media criterion?

No. Wikipedia:

  • Is an encyclopedia, not a media outlet
  • Content is user-created
  • Can be used for Final Merits as recognition, but not as primary evidence
RFE example: Wikipedia and web portals + case law

Case law — Lamilem Badasa v. Mukasey

“Wikipedia, web portals, domains, blogs, social media: there are no assurances about the reliability of the content from these open, user-edited Internet sites. See Lamilem Badasa v. Michael Mukasey, 540 F.3d 909, 901-11 (8th Cir. 2008). Therefore, any documentation from Wikipedia, web portals or social media sites carry no evidentiary weight within the present proceedings.”

Court precedent: the court confirmed that open, user-edited sites have no evidentiary weight.

Wikipedia — explicit rejection

“Wikipedia is an online, open source, collaborative encyclopedia that explicitly states it cannot guarantee the validity of its content. See General Disclaimer, Wikipedia.”

The officer cites Wikipedia's own disclaimer — the encyclopedia admits it cannot guarantee content validity.

Wikipedia, IMDb, Instagram — explicitly rejected

“Web portals, company websites, social media, and search engines not subject to editorial review are open to self-creation of material. There is no assurance of reliability from open or user-edited internet sites. See Badasa v. Mukasey, 540 F.3d 909, 901-11 (8th Cir. 2008). Therefore, the material provided from these sources (Wikipedia, IMDb, Instagram, etc.) carries no evidentiary weight within the proceedings.”

The officer lists specific sources: Wikipedia, IMDb, Instagram — "no evidentiary weight."

IMDb — detailed criticism with disclaimer

“You submitted your biography and other documents from the Internet Movie Database (IMDb), but there are no assurances about the reliability of the content from this open, user-edited Internet site. See Lamilem Badasa v. Michael Mukasey, 540 F.3d 909 (8th Cir. 2008). According to the IMDb, information on the website comes from various sources, and includes ‘press kits, official bios, autobiographies, and interviews’ as well as ‘people in the industry and visitors.’ The site indicates that while efforts are made to keep the information as ‘accurate and reliable as possible,’ ‘occasional mistakes are inevitable.’ Therefore, we shall not assign weight to information for which IMDb is the only cited source.”

The officer quotes IMDb's disclaimer: the site itself admits information comes from various sources including users and may contain mistakes. The officer will not assign weight when IMDb is the sole source.

Web portals ≠ publications

“Websites that are portals or offer services from news, opinions, blogs and videos to network platforms for business do not qualify as they combine both professional media and user generated content as well as material targeted to regional interests, therefore it cannot be determined where the postings originated or that they are objective, credible, and reliable.”

Web portals mix professional and user-generated content — you cannot determine origin or objectivity.

Why journals differ from portals

“Journals and major media require an editorial or peer review process to ensure a level of objectivity, reliability and accuracy.”

Real media have editorial or peer review processes. That distinguishes major media from user-generated portals.

What is not accepted

“International accessibility via the internet (such as postings in blogs, social media, web portals, search engines, podcasts, webinars, training portals, user-created content or an organization’s website) is not commensurate with ‘major media’ in the United States or any other country as required under the regulation at 8 C.F.R. § 204.5(h)(3)(iii).”

Full list: blogs, social networks, portals, search engines, podcasts, webinars, training portals, user-generated content, or an organization’s website — none are major media by default.

“Anyone with a computer can create a website”

“While internet websites can be accessed worldwide, we cannot ignore that anyone with a computer can create a website. Not every brief mention on a website can be considered published material about the petitioner appearing in major media.”

The officer states a fundamental problem: global accessibility ≠ major media.

Sites allow account creation

“While the self-petitioner submitted some documentation to support the size of the websites’ audience, it does not demonstrate that the websites are authentic news sources, as many websites act as platforms that allow individuals to create their own accounts and publish their own articles. Therefore, the evidence did not demonstrate that the websites are reliable sources of information.”

Audience size alone does not prove an authentic news source. Many sites are platforms for self-publishing.

T Adviser and ArtMoskovia — denial

“The record provided material disseminated by web portals; however, web portals are not publications.”

The officer: "web portals are not publications." T Adviser and ArtMoskovia were classified as portals.

Officer conclusion

"As such, the submitted evidence does not meet the plain language for this criterion."

The criterion was not met even at the first stage (plain language). Web portals = automatic rejection.

Specific list of sites rejected as “web portals”

“You provided articles from web portals such as sostav.ru, similarweb.com, dzenn.ru, snob.ru, vc.ru, banya.ru, andreysechin.medium.com, businessstory.ru, youtube.com, instagram.com, gazeta.ru, kp.ru, rosbalt.ru, daptar.ru, coverjournal.com, sm.news, et al. However, the evidence does not show that the posted material was published in a professional or major trade publication.”

Even well-known Russian outlets (Gazeta.ru, KP) were classified as "web portals".

Sports sites as web portals

“You provided materials from web portals (matchtv.ru, championat.com, sports.ru, sportsdaily.ru, metaratings.ru). With regards to web portals and/or domains, there are no assurances about the reliability of the content from these open, user-edited Internet sites. See Lamilem Badasa v. Michael Mukasey, 540 F.3d 909, 901-11 (8th Cir. 2008). Therefore, any documentation from web portals or domains sites carry no evidentiary weight within the present proceedings.”

Match TV, Championat, Sports.ru were classified as "web portals."

Rejected (sport): matchtv.ru, championat.com, sports.ru, sportsdaily.ru, metaratings.ru

IT/Telecom sites — insufficient evidence

“You provided web printouts/articles from trends.rb.ru, vedomosti.ru, probusinesstv.ru, comnews.ru, telcomdaily.ru, et al.; however, you did not provide sufficient evidence to demonstrate that the material was published in professional or major trade publications or other major media.”

Even Vedomosti and RB.ru require separate proof of major status.

Film/media sites — extended list

“You provided articles from web portals such as redner.ru, imdb.com, cerebrohq.com, thealmostdone.com, sbwire.com, articlesreader.com, speakerhub.com, youtube.com, yandex.ru, et al. However, the evidence does not show that the posted material was published in a professional or major trade publication, or if it was reported in major media.”

Even professional tools (Cerebro) and industry platforms are not considered major media.

Rejected (film/media): imdb.com, cerebrohq.com, thealmostdone.com, sbwire.com, speakerhub.com, youtube.com, yandex.ru

Kazakh sites as web portals

“The petitioner has provided several articles from web portals, such as alau.kz, kazpravda.kz, qostanay.tv, and altyn-orda.kz. However, the evidence does not show that the posted material was published in a professional or major trade publication, or that it was reported in major media.”

Kazakh news sites were classified as "web portals" without evidence of major status.

Rejected (Kazakhstan): alau.kz, kazpravda.kz, qostanay.tv, altyn-orda.kz, kstnews.kz, vecher.kz

Chinese portals — full rejection list

“With regards to Wikipedia, web portals, domains, blogs, podcasts and social media, there are no assurances about the reliability of the content from these open, user-edited Internet sites. See Lamilem Badasa v. Michael Mukasey, 540 F.3d 909, 901-11 (8th Cir. 2008). Therefore, any documentation from Wikipedia, web portals (qq.com, ifeng.com, china.com, sohu.com, baidu.com, sina.com, 163.com, xinhuanet.com, etc.), domains, blogs (medium.com), or social media sites (weixin.qq.com, vk.com) carry no evidentiary weight within the present proceedings.”

Even large Chinese outlets (Xinhua, Sina, Baidu) were classified as "web portals" with no evidentiary weight.

Rejected (China): qq.com, ifeng.com, china.com, sohu.com, baidu.com, sina.com, 163.com, xinhuanet.com, weixin.qq.com

Business/IT portals — “domains are not publications”

“We note that the petitioner offers online material disseminated by u-f.ru, business.ru, spb.aif.ru, mir24.tv, but these appear to be from web portals or domains. The material is not published, these domains are not publications, and web portals are open to user-created and marketing content.”

Important distinction: "domains are not publications." Even if a site looks like media, the officer may classify it as a "domain."

Rejected (business/IT): u-f.ru, business.ru, spb.aif.ru, mir24.tv, vc.ru, tproger.ru, rb.ru

Niche sites without proof of major

“You have not presented any credible third-party or corroborated evidence demonstrating that crushthat.com is a major trade publication, or other major media as required by 8 C.F.R. 204.5(h)(3)(iii). To qualify as major media, the publication should have significant national or international distribution, or viewership is high compared to other websites.”

For any site you must show: (1) significant national/international distribution, OR (2) high viewership compared to peers.

Why web portals are rejected — detailed explanation

“Web portals, company websites, social media, and search engines not subject to editorial review or open to self-creation of material. Because it is not evident whether users come to the websites intentionally or are redirected unintentionally, web traffic is not directly comparable to circulation. There is no assumption of reliability from open or user-edited internet sites.”

The officer explains logic: (1) no editorial control, (2) self-publication possible, (3) traffic ≠ circulation, (4) no guarantee of reliability.

Mention in a university graduates list?

Not acceptable for this media criterion:

  • A university site is not a media outlet
  • Use it for Final Merits

RFE on the media criterion

From practice: RFE analysis

The "Published Material" criterion is in the top-3 for number of RFEs. From 300+ studied cases: 45% of denials relate to unproven major status, 30% — article not "about you", 15% — missing author/date, 10% — paid content.

Typical reasons for RFE on media?

Common officer objections:

  • Outlet is not proven as major (insufficient data)
  • Article is not “about the alien” (about company, not you)
  • Paid content / advertisement
  • Missing author or publication date
Approval example: what worked

What was submitted

“In support of this criterion, you submitted articles from: www.eg.ru; www.tadviser.ru; Cover letters citing Similarweb statistics”

Small issue:

“You also submitted an article from The General Director. However, the article lacks an author and publishing date.”

One article without author/date — but this did not prevent approval.

Result

“USCIS has reviewed the evidence submitted in support of this classification and has determined that you have established eligibility under this regulatory criterion.”

The criterion was counted! Effective combination: eg.ru + tadviser.ru + SimilarWeb data in cover letters.

Why it worked:

  • eg.ru (Express-Gazeta) and tadviser.ru — known outlets
  • SimilarWeb data attached in cover letters (not standalone)
  • Despite one problematic article, the rest sufficed
Approval example #2: KP and Informio accepted

What was submitted

"The petitioner submitted material from the following: - 'Creativity and innovation: Teacher of Fine Arts - about lessons in modern schools' published on July 27, 2024, by Svetlana Borisova - 'Uncovering Talents: interview with Fine Arts Teacher Evgeniia Zaevskaia' published April 17-24, 2024, by Evgeniy Arsyukhin on www.kp.ru Komsomolskaya Pravda - 'Only when you close your eyes before going to sleep...' by P.S. Chernyshov published on December 2, 2023, on Informio"

Small issue:

“The translation of the article by Svetlana Borisov does not include the publication name, therefore, the USCIS cannot determine the type of media publication this article was found.”

One article rejected — its translation lacked the outlet name.

Result

“However, the evidence indicates that the remaining publications are professional or major trade or other major media publications. Therefore, the plain language of the criterion has been met.”

The criterion was accepted! Komsomolskaya Pravda (kp.ru) and Informio were accepted as major media.

Why it worked:

  • Komsomolskaya Pravda — a known Russian outlet
  • All articles had title + date + author
  • Despite one problematic article, others were sufficient
Approval example #3: Massage therapist — kp.ru, zdrav.expert, beautyhunter.ru, apni.ru

What was submitted

"Media Report - Interview: 'The Future of Massage Trends and Prospects' With massage therapist-expert [Name] about the development of the industry and forecast for 2023 - Author: [Author] - kp.ru - November 9-16, 2022; Media Report - [Name]: 'Massage can help effectively cope with stress and anxiety' - www.kp.ru - August 1, 2024; Media Report - [Name]: 'It is important to influence the body not only on a physical level' - zdrav.expert - August 15, 2024; Media Report - Lymphatic Drainage Massage: Secrets of Youth After 50 - beautyhunter.ru - April 14, 2024; Media Report - Revolution in massage - apni.ru - April 25, 2024"

Result

“The petitioner submitted published material from kp.ru, zdrav.expert, beautyhunter.ru, and apni.ru. The material was written about the petitioner and her work in the field. As such, the submitted evidence meets this criterion.”

The criterion was accepted! All four outlets were accepted as major media.

Key to success

Mix big outlets (kp.ru) with niche, industry-specific publications (zdrav.expert, beautyhunter.ru). Niche outlets for your industry also work!

Example DENIAL: SM.news, kp.ru - interviews accepted, but major not proven

What was accepted

“Only your interview articles from SM.news and kp.ru were considered under this criterion.”

The officer acknowledged that interviews on SM.news and kp.ru are articles ABOUT YOU. First barrier passed.

Why denied

“Nevertheless, you have not presented credible third-party or corroborated evidence to demonstrate the national or international circulation of the organization(s) that printed or distributed any of these submitted articles, or to otherwise show that these sources are professional, major trade publications, or other major media publications.”

Articles about you — but you did not prove the outlets are major. SimilarWeb alone is insufficient.

Lesson

Even if the article is ABOUT YOU in a known outlet (kp.ru) — you must separately prove the outlet's major status. SimilarWeb alone = RFE.

IMPORTANT: kp.ru labeled a tabloid — denial!

Shocking officer position

“The petitioner submitted an article published on kp.ru. However, it appears to be a tabloid newspaper. Tabloid newspaper coverage is generally insufficient to satisfy this criterion because generally characterized by sensationalism and entertainment-focused content, and are not widely recognized as reputable sources of professional or major media coverage. As such, kp.ru does not meet the regulatory standard of major media as intended under 8 CFR 204.5(h)(3)(iii).”

The officer called Komsomolskaya Pravda a "tabloid" — sensational and entertainment-focused. This CONTRASTS with approvals that accepted kp.ru in other cases!

Contrast with other decisions:

  • In some cases kp.ru is accepted as major media
  • In others it is rejected as a “tabloid”
  • The outcome depends on the officer and context

KP.RU is a lottery

One officer accepts it, another calls it a tabloid. Do not rely SOLELY on kp.ru — add industry-specific outlets.

RFE example: insufficient data about major media

Officer template text

“This criterion has not been met because the evidence does not indicate that the published material was published in professional or major trade publications or other major media. The evidence of record indicates the media sources are not major media as they do not appear to have significant readership or visits especially when compared to notable major media sources such as The New York Times, and The Wall Street Journal.”

The officer says: your outlets do not measure up to NYT or WSJ. These are used as benchmarks.

What the officer requires:

  • The title, date, and author of the published material
  • The circulation (online and/or print)
  • The intended audience of the publication

Important clarification

“The evidence submitted should be specific to the media format in which it was published. If the material was published online, the evidence should relate to the website. If it was published in print, the evidence should relate to the printed publication.”

For online articles provide website data; for print provide circulation data.

Why SimilarWeb alone is insufficient?

SimilarWeb — a red flag for officers

If you prove a publication's major status ONLY via SimilarWeb, expect an RFE. Officers often criticize this source as insufficient.

What’s wrong with SimilarWeb:

  • Officers consider it not authoritative enough
  • Data can be inaccurate for smaller sites
  • Does not show the outlet’s history and reputation
  • One source = weak evidence

Correct strategy — combine sources:

Source What it adds Priority
SimilarWeb/SEMrush Traffic and rankings Basic, but not alone
Medialogia / Mediascope Official Russian media ratings High for Russian media
Media Kit of the outlet Audience, awards Medium (self-serving!)
Citations by other media Industry recognition High
Comparison with peers Context of significance High
Quotes from RFEs: why SimilarWeb/SEMrush is insufficient

Objection: no independent evidence

“The petitioner submitted articles about himself related to his work published in Amazing Architecture, Design and Survey Construction Works, Stroitelnaya Gazeta, and Komsomolskaya Pravda but submitted no independent, probative evidence that they are in major trade publications or other major media.”

The officer says: you attached articles but DID NOT PROVE these outlets are major. Articles alone are not proof of outlet status.

Objection: self-serving data

“While the petitioner submitted readership and circulation data, a majority of the data came from the publications’ own websites. We do not accept self-serving assertions of circulation data.”

The officer says: data from the outlet's own website is self-serving. An outlet praising itself is not independent evidence.

Objection: bounce rate and visit duration

“Statistics such as visit duration and bounce rates are not indicative of major media status.”

User behavior metrics are not indicators of major status. Those are marketing metrics, not USCIS criteria.

Objection: “About Us” pages not accepted

“USCIS cannot ignore the fact that all of the materials submitted from the web sites’ ‘about us’ pages were prepared by the web sites themselves. Self-generated materials will, by nature, paint their own publications in the most high regard to generate advertisement revenue, participation and increase readership. Such materials are not independent evaluations of the major status of the medium.”

"About Us" is marketing copy for advertisers. Officers treat it as self-promotion, not independent proof.

Objection: SEMrush without comparison is useless

“A complete review of the semrush printouts indicates these are static figures for marketing purposes. While these printouts address metrics such as visits, unique visitors, pages/visit and average visit duration, there is no comparative data by which to measure the metrics for these specific web sites. For example, the semrush printout for [site] indicates a unique visitors number of 12.7k. Now, is this per day, per month or per year? Are these numbers low, average or high compared to known major media outlets such as the New York Times or the Wall Street Journal? Without a comparative aspect the information from semrush is not indicative of major media status.”

The officer literally asks: "Is 12.7K a lot?" Without comparison to NYT/WSJ or peers numbers are meaningless.

Objection: specific figures used in denial

“USCIS has reviewed the similarweb printout for [site]. According to this printout the website generated 1.826 million visits from August, 2024 through October, 2024. That visit total placed [site] as the 27,083 most popular website in the United States, and the 3,147 most popular website in the computer and electronics industry. Given these low ranks USCIS cannot conclude that [site] is a major media source, even within the industry.”

Even 1.8 million visits over 3 months — insufficient. Rank #27,083 in the US and #3,147 in the category = "low ranks." Major media should rank much higher.

Precedent Braga v. Poulos

"See Braga v. Poulos, No. CV 06 5105 SJO (C. D. CA July 6, 2007) aff'd, 317 F. App'x 680 (9th Cir. 2009) (concluding that the AAO did not have to rely on self-serving assertions on the cover of a magazine as to the magazine's status as major media)."

The court confirmed that USCIS may refuse to rely on self-serving assertions by publishers. Officers cite this as legal basis.

Precedent Victorov v. Barr (2020)

"USCIS need not rely on the publisher's self-promotional material. See Braga v. Poulos, No. CV 06 5105 SJO (C.D.C.A. July 6, 2007) aff'd 2009 WL 604888 (9th Cir. 2009); see also, e.g., Victorov v. Barr, No. CV 19-6948-GW-JPRX, 2020 WL 3213788, at *8 (C.D.C.A. Apr. 9, 2020)."

Victorov v. Barr (2020) — a more recent precedent supporting Braga. Officers cite both cases to strengthen the argument.

Precedent Krasniqi v. Dibbins (2021) — "publication's own say so"

"USCIS is not required to rely on the self-promotional material of the publisher and 'we may require more than the publication's own say so that it is major.' Krasniqi v. Dibbins, 558 F. Supp. 3d 168, 185 (D.N.J. 2021) (citing Braga v. Poulos)."

Krasniqi v. Dibbins (2021) — another recent precedent. Key phrase: USCIS may require "more than the publication's own say so".

Matter of Treasure, Craft - assertions without evidence
Court Precedent
"In the cover letter, Counsel has included information about the publications, but simply going on record without supporting substantive evidence to support assertions, is not sufficient to meet the burden of proof in these proceedings. See Matter of Treasure Craft of California, 14 I&N Dec. 190 (BIA 1972)."

Important precedent: an attorney's cover letter listing publications is not enough without substantive supporting evidence.

Objection: website analytics alone do not prove major

“While the petitioner provided website analytics and ranking data, these statistics alone do not demonstrate that the publications qualify as major media. The evidence must establish that the publication has significant national or international distribution and is considered a professional or major trade publication in the field.”

The officer says: website analytics and rankings alone are not enough. Evidence must show significant national/international distribution and industry recognition.

Objection: promotional materials not accepted

“Furthermore, some of the submitted materials appear to be promotional in nature or were created for marketing purposes, which generally do not satisfy this criterion. The published material should be independent coverage about the beneficiary’s work in the field, not advertising or self-promotional content.”

The officer notes: materials look promotional rather than independent coverage.

Broadcast certificates = self-serving

“You provided evidence from ProBusiness TV, comnews.ru, telecomdaily.ru, et al. such as Broadcast certificate and printouts about their own organizations; however, USCIS need not accept self-serving assertions of information data. See Braga v. Poulos.”

Certificates and information from the outlet itself are self-serving and may be disregarded per Braga v. Poulos.

SimilarWeb is a traffic tool, NOT a circulation tool

“You provided data from similarweb.com which is a tool to broadly determine internet domain traffic, not to determine a publication’s circulation. Material on the internet can include many types of domains, not all are objective or vetted in the manner of major media and publications with editors or peer review. General web domain statistics offer inappropriate comparisons that are not useful to determine whether a source is major media commensurate with this criterion.”

The officer states: SimilarWeb measures domain traffic, not publication circulation. Domain stats are not appropriate comparisons to determine major media status.

IMPORTANT: USCIS acknowledges that SimilarWeb is NOT self-serving

“USCIS acknowledges that SimilarWeb analytical data would not be considered self-serving or promotional data, and that the application of Braga does not apply in this regard. However, the SimilarWeb data does not establish that the submitted evidence demonstrates the articles were published in professional or major trade publications or other major media.”

Important nuance: the officer concedes SimilarWeb data is not inherently self-serving (unlike a media kit), BUT even so SimilarWeb alone does not establish that the articles were published in major media.

Officer demand: at least TWO analytics sources

“The circulation statistics for the publications are to be compared against at least two separate media traffic analytics (not the publisher) that are in the beneficiary’s field during the same timeframe of the beneficiary’s publications, in the same format (daily, weekly, monthly, quarterly, volume, episodic, annually) and in the same field of endeavor.”

Concrete officer request: you need at least TWO independent analytics sources (not from the publisher). Comparison must be in the same field and same time frame with the same measurement format.

render.ru — denial example with specific rankings

“The petitioner points to SimilarWeb data showing the number of visits to the websites of the various publications, but raw numbers do not provide the comparison to other circulation figures required by the USCIS Policy Manual guidance. SimilarWeb data does provide comparative evidence in the form of rankings by country and category, as well as globally. A review of these rankings do not establish these publications as a major trade publication or other major media. For example, render.ru has a global rank #131,250, country rank #8,110 and industry rank #90.”

Concrete example: render.ru with global rank #131,250, country rank #8,110, industry rank #90 — rejected as NOT major. The officer says: these rankings do not show a major outlet.

siteworthtraffic.com — another traffic tool rejected

“You provided data from siteworthtraffic.com which is a tool to broadly determine internet domain traffic, not to determine a publication’s circulation. Material on the internet can include many types of domains, not all are objective or vetted in the manner of major media and publications with editors or peer review. General web domain statistics offer inappropriate comparisons that are not useful to determine whether a source is major media commensurate with this criterion.”

Same criticism applies to siteworthtraffic.com as to SimilarWeb.

pr-cy.io — a Russian traffic tool also rejected

“You provided data from similarweb.com, pr-cy.io which are tools to broadly determine estimations of internet domain traffic or visits and/or rankings, and/or pageviews, not to determine a publication’s circulation, readership and/or viewership.”

pr-cy.io was rejected for the same reason: traffic estimation ≠ circulation data.

“Reported visits not reliable indicator”

“USCIS finds the information from similarweb.com is relied upon in media and other industries to evaluate website traffic and other performance indicators. However, USCIS finds the figures provided are insufficient to show that any of the websites qualifies as ‘other major media’. Thus, USCIS finds reported visits are not a reliable indicator of the number of people visiting the site, and thus of each publication’s online circulation.”

Interesting phrasing: the officer acknowledges SimilarWeb is used in industry but deems "reported visits" not a reliable indicator of unique audience and circulation.

Pageviews ≠ circulation (detailed explanation)

“USCIS notes, that circulation, readership and/or viewership of published material is not the same as visitation and/or pageview and rankings of published material. Circulation is a count of how many copies of a particular publication are distributed. Readership is an estimate of how many readers a publication has. Viewership is a count of visitor loads or reloads of a page that they chose to view. Visits and/or pageviews occurs when someone lands and/or is redirected to a site from an external page such as Google or another website but did not choose to go to that site.”

The officer explains the difference: circulation = copies distributed; readership = estimated readers; viewership = counts of intentional views; visits/pageviews include accidental redirects. Pageviews include random traffic and are not equivalent to an audience.

Self-manufactured editorial comments — where did the data come from?

“What appear to be self-manufactured editorial comments regarding articles and publication information were supplied in multiple documents without a foreign language original source. For example, Exhibit 93 stated, 'The article highlights Mr. [Name]‘s involvement as a member of the Board of Directors… actively promoting the tannery’s products…’ The document proceeds to cite a title, author, date and link to the publication and brief overview of the Business Journal of Bashkortostan. It is not apparent where the circulation and distribution information originated, please explain.”

The officer noticed that the petitioner created their own summary documents with commentary and provided circulation figures without indicating the source. "It is not apparent where the circulation and distribution information originated" — the officer asks you to explain the origin of each figure.

Rule about sources

If you prepare consolidated lists about articles — specify the source for every figure. "Circulation 500,000" — where did it come from? From the outlet's site? From Medialogia? The officer will check.

SimilarWeb did not convince the officer — alternatives?

Additional sources:

  • Alexa (archival data via Wayback)
  • SEMrush / Ahrefs
  • Outlet media kit
  • Medialogia ratings
  • Mediascope data (for TV/radio)

How to respond to an RFE on media?

Response structure:

  1. Additional data on each outlet
  2. Comparison with well-known publications
  3. Expert letters on outlet significance
  4. Explanation of publication context

RFE requests prove major — what to do?

  1. Collect all available metrics (traffic, circulation, rankings)
  2. Compare with US analogues
  3. Show citations by other media
  4. Add an expert letter from a media specialist

Expert letters — not automatic proof!

Officers apply precedent Matter of Caron and Matter of V-K- which limit the weight of expert opinions. Objective data (statistics, rankings) are necessary.

RFE example: expert letters ≠ proof

Explanatory note = “simply an opinion”

“The explanatory note from [Name] is simply an opinion. Furthermore, the submission of solicited letters supporting the petition is not presumptive evidence of eligibility. See Matter of Caron International, 19 I&N Dec. 791, 795 (Comm. 1988); see also Matter of V-K-, 24 I&N Dec. 500, n.2 (BIA 2008) (noting that expert opinion testimony does not purport to be evidence as to ‘fact’).”

Officer cites two important precedents:

  • Matter of Caron (1988): solicited letters are not presumptive evidence
  • Matter of V-K- (2008): expert opinion ≠ evidence of fact

Conclusion: an expert letter about the outlet is an opinion, not a fact. Objective metrics are required (statistics, rankings).

“Online material about other online material” — does not work

“Simply submitting online material about other online material whose veracity and legitimacy cannot be determined has no probative value.”

You cannot just submit an article about an outlet (e.g., Wikipedia about an outlet) as proof. The officer cannot verify such sources' legitimacy.

Technical requirements

How to properly submit an online article?

Screenshots = altered document!

Officers reject screenshots pasted into Word or Google Docs. This is considered "self-made documentation" and "undermines credibility."

What NOT to do:

  • Take a screenshot, scroll, take another screenshot, paste into Word/Google Docs
  • Cut parts of the article and paste into your document
  • Resize or crop images
  • Remove parts of the page

Correct method — save PDF in original format:

Method How to do
Print to PDF Ctrl+P (Cmd+P) → “Save as PDF” - saves the page as is
GoFullPage Chrome extension — captures the ENTIRE page into PDF
Firefox Screenshot Right click → “Take Screenshot” → “Save full page”

Requirements for each PDF page:

  • Visible URL address
  • Page number
  • Original size and format
  • Save date (in file name or on the page)

GoFullPage — most reliable method

The extension scrolls the page automatically and creates a single PDF with all content. The URL is visible in the browser header on the screenshot.

RFE example: altered copies are not accepted

Detailed requirements for webpage screenshots

“With respect to documents from the Internet, you must submit webpage screen shots (including the URL address and page number on each page) as they would appear on the original source’s website. You submitted webpage screen shots not as they appear (did not include the URL address and page number on each page) on the original source’s website.”

Each screenshot page must include: (1) URL address, (2) page number. Without that — "not as they appear on original source."

Cut-and-paste = undermines credibility

“It appears you submitted self-made documentation where you pasted specific portions of information (text, pictures, etc.) from the original webpage (articles or information). This undermines the credibility of this documentation because it did not originate from the original source.”

If you cut pieces of the article and pasted into your document — this "undermines credibility."

No full URL = no probative weight (Matter of Treasure Craft)

“With respect to documents from the Internet, the petitioner did not submit evidence that shows the full URL address on each page in order for the source to be identified. Therefore, no way to independently and objectively verify their originality. As such, this article is given no probative weight. See Matter of Treasure Craft of California, 14 I&N Dec. 190 (BIA 1972).”

Officer cites Matter of Treasure Craft: without a full URL on each page — "no way to independently and objectively verify originality." Result: ZERO probative weight.

Digital, self-made copies = inadmissible

“The petitioner submitted digital, self-made copies of documentary evidence that you reduced or altered, but such documentation is inadmissible. You must submit legible, non-digital photocopies or computer printouts directly from publications of all original documentary evidence, reflecting their original size.”

The officer says: you altered size or edited documents — such copies are inadmissible. Submit legible photocopies or computer printouts from the original publication in original size.

Why URL and page numbers are critical

“Internet webpage screen shots lacking an URL address and page numbers from the original source are of little probative value as the statements or assertions contained therein cannot be corroborated, nor can we verify the screen shot is complete and accurate.”

Without URL and page numbers the officer cannot: (1) verify the source, (2) confirm the screenshot is complete and accurate. Result = "little probative value."

Illegible and incomplete copies

“You have submitted copies of digitized evidence that appear illegible and incomplete. The material that you provided as evidence includes digitized material, possibly scanned, and some altered with handwriting and cut and pasted information on the copies. This material is not reliable documentation, nor does it comply with the regulatory requirements at 8 C.F.R. § 103.2(b)(3).”

The officer says: illegible scans, handwritten notes, cut-and-paste — not reliable and do not meet 8 CFR 103.2(b)(3).

Quality vs quantity (Chawathe)

“Eligibility is to be determined not by the quantity of the filings alone but by their quality. Chawathe, 25 I&N Dec. at 376 (citing Matter of E-M-, 20 I&N Dec. 77, 80 (Comm’r 1989)). We ‘examine each piece of evidence for relevance, probative value, and credibility, both individually and within the context of the totality of the evidence.’”

The officer stresses: quantity does not equal quality. Each piece is examined for relevance, probative value and credibility. Chawathe is the standard citation.

Maximum detailed instruction

“Digital, self-made copies of documentation (recommendation letters, membership documents, internet webpages, etc.) that includes altered material or information pasted (text, pictures, dates, etc.) into a self-created document will not be given probative value. You must submit ‘ordinary legible photocopies’ of all original documentary evidence, reflecting their original size. Do not submit digital photos or scans of documentary evidence that are pasted in to a document, altered, or photoshopped.”

The officer explicitly forbids: (1) pasting into Word/Google Docs, (2) resizing, (3) photoshopping, (4) cutting pieces. They require "ordinary legible photocopies" at original size.

Self-made documents “severely undermine credibility”

“With respect to documents from the Internet, you must submit webpage screenshots (including the URL address on each page) as they would appear on the original source’s website. You submitted webpage screenshots not as they appear (when searching the stated URL address) on the original source’s website. Instead, you submitted self-made documentation where you pasted specific portions of the webpages’ information (text, pictures, etc.) from the original webpage (articles or information). This severely undermines the credibility of this documentation because it did not originate from the original source.”

"Severely undermines credibility" — a strong phrase. If the officer finds your document differs from the original, pasted pieces = credibility undermined.

Why self-made documents are not accepted

“Furthermore, you were solely responsible for what content was included (which is not independent nor objective), not the original source, and it is not clear whether the submitted documents were complete (and completely translated). In addition, many of your self-made documents included text (including URL addresses, dates, authors names, etc.) that were illegible. Consequently, we did not consider any of this self-made material.”

Three problems: (1) you chose content — "not independent nor objective", (2) unclear whether the document is complete and fully translated, (3) illegible text. Result: "we did not consider any of this self-made material."

How to fix — direct officer instruction

“If you want USCIS to fully credit the material you have submitted from the internet, re-submit the webpages (webpage printouts) as they would exactly appear on the original source’s website/webpage, with the full URL address.”

The officer gives clear instruction: "webpage printouts as they would exactly appear" + full URL. Use Print to PDF or GoFullPage.

What is the minimum article length (characters)?

There is no formal minimum. Guidelines:

  • 400+ words — minimum
  • 800+ words — good
  • 1500+ words — excellent

Quality and depth matter more than length.

Photo license fee — should it be indicated?

No, not relevant for USCIS. Important only:

  • Photo credit with your name
  • Photo used in context of an article about you

Newspaper with circulation 50,000 — is that major?

Depends on context:

  • For a city of 100K population — yes, major
  • For a country of 150M — needs more justification
  • Compare with other outlets in the category

How to handle paywalled articles?

  1. Save via Print to PDF or GoFullPage (do not paste screenshots into Word!)
  2. If paywall blocks, try Wayback Machine
  3. Indicate: “Full article behind paywall, PDF attached”
  4. Attach outlet information separately

Article removed from the web — how to use?

  1. Wayback Machine — find archived copy
  2. Save via Print to PDF with URL and archive date
  3. If no archive — use any saved copies you have
  4. Explain in the petition why the article is unavailable

Print vs online — is there a difference?

For USCIS there is no difference. But:

  • Print: harder to fake, appears stronger
  • Online: easier to show traffic and reach

Both formats are equally valid when proving major status.

Must the outlet be officially registered?

Official registration as a media outlet is not required. USCIS looks at:

  • Audience and reach
  • Editorial control
  • Industry recognition

Many large online outlets are not registered as “media” in a legal sense.

Article in a mobile app — how to prove?

  1. Screenshots from the app with date
  2. App info (App Store/Google Play)
  3. Audience metrics for the app
  4. If web version exists — use that

Only online outlets without print — acceptable?

Yes. By 2024 many major media are online. Criteria remain:

  • Significant national or international distribution
  • Editorial control
  • Industry recognition

Can you get the visa without media?

Is it realistic to obtain O-1/EB-1A without the media criterion?

Yes. Media is one of 10 criteria, not mandatory:

  • You must meet 3 criteria (EB-1A) or the standard (O-1)
  • Many succeed without media
  • IT specialists often rely on authorship + contributions

Which criteria can replace media?

Popular alternatives:

  • Authorshipscholarly articles, patents
  • Judging — peer review, jury service
  • Contributions — significant original contributions
  • High Salaryhigh compensation
  • Awards — industry prizes and recognition

IT specialists without media — strategy?

Typical IT case without media:

  1. Authorship (conference papers, patents)
  2. Contributions (products, open source)
  3. Judging (code review, peer reviewing)
  4. High Salary

Weak media — better to omit?

Depends:

  • 1-2 weak media references are better omitted
  • Weak media can weaken the whole case
  • Focus on stronger criteria

Field-specific nuances

IT/Tech — which outlets count?

Suggested outlets:

  • TechCrunch, Wired, The Verge (major)
  • IEEE Spectrum (professional)
  • Industry portals with editorial control
  • NOT: Habr, Medium, HackerNoon (as primary sources)

Business/Entrepreneurship — which outlets?

Recommended:

Sports — how to present media coverage?

For athletes:

  • Articles about competitions that focus on you
  • Interviews in sports media
  • Reports on your performance with a focus on your achievements

Competition results ≠ published material

Officers explicitly state: "gameplay or player statistics" are not considered substantial published material about you. Competition results are data, not articles ABOUT YOU.

RFE example: newsru.co.il — article about championship ≠ about YOU

Officer criticism

“You submitted an article from newsru.co.il that only mentions you and where you placed in competition. This material is about the results of the 2022 European Ballroom Dance Championships and not ‘about’ you. Published material must not simply be about the results of a ballroom dance competition, but about you–though it may not be unrelated to your work. Your accomplishments in the wider field should be the focal point of the published material.”

Specific example: an article about the 2022 European Ballroom Dance Championships. The officer says: it is about the competition results, not ABOUT YOU. The officer requires a substantial evaluation of your accomplishments.

RFE example: dance sport results rejected

Officer criticism

“You have submitted what appear to be one article and dance sport competition results and synopsis. You have submitted articles that appear to be missing one of these three pieces of information: title, date or author and this evidence therefore cannot be considered probative.”

The officer says: dance competition results are not "published material about you" — they are event results and not substantive articles.

What does NOT count for athletes:

  • Results tables
  • Game/match statistics
  • Rankings and standings
  • Event synopses

What counts:

  • Feature stories about your career
  • Interviews in sports media focusing on you
  • Feature articles with substantial discussion of your achievements

Multiple mentions of an event — make a compilation or individual files?

If many mentions from one event — create a compilation exhibit with the 5-10 best examples. No need to submit 50 separate screenshots.

Article about a championship — show seasons participation or past ones?

Include all relevant items, but focus on those where you are specifically mentioned. Past seasons provide context for the event’s significance.

Creative professions — which publications?

For designers, artists:

  • Specialized magazines (Dezeen, ArchDaily)
  • Exhibition reviews in media
  • Interviews in lifestyle outlets if they focus on your work

Reprints and syndication

Are reposts by other outlets counted separately?

No. Reprints are not separate publications:

  • Indicate the original source
  • Reprints can be noted as “distributed across X outlets”
  • Do not count them as multiple distinct publications

Syndicated content — how to handle?

Syndication (AP, Reuters) requires special handling:

  • Indicate the original source
  • Show distribution reach
  • Focus on the quality of the original

Article in two languages (original + translation) — two sources?

No. This is one publication in two versions:

  • Cite the original as the primary source
  • The translation demonstrates international reach
  • Do not count as two separate articles

Article in a partner section — acceptable?

Depends on the section:

  • “Partner Content”, “Sponsored” — no
  • Section with editorial control — may be acceptable
  • Check for advertising labels

Press release reposted on Yahoo Finance — is it media?

No. Press releases on Yahoo Finance, MarketWatch, BusinessWire:

  • Not editorial
  • Paid placement
  • Officers can distinguish them

Use them for Final Merits as proof of PR activity, not for Plain Language.

Edge cases

“As told to” format — is it an article about you?

Yes, “As told to” is an article about you:

  • A journalist recorded your story
  • Editorial processing occurred
  • It is a standard journalistic format

Ghostwritten article under your name — how to use?

An article authored under your name ≠ article about you:

  • Does not count for the media-about-you criterion
  • Use it for Authorship or Contributions
  • Use it for Final Merits

Interview you initiated — is it a problem?

Not necessarily. Many interviews are initiated via PR:

  • The key is the result: an editorial publication
  • You do not need to disclose how the interview started
  • The officer does not investigate the process

Must there be an invitation from the media?

Not required, but helpful to show:

  • Editorial content (not paid)
  • The media independently chose you
  • Recognition as an expert

Journalist friend wrote the article — conflict?

Formally not a problem, but:

  • Article must be in a major outlet
  • Editorial control must be apparent
  • Do not disclose personal connections

Is there a USCIS blacklist of media?

No. There is no blacklist. Outlets commonly used without issues:

  • Russian: KP, RBC, Izvestia, TASS, Forbes Russia, Pravda.ru
  • International: Forbes, TechCrunch, Wired, The Verge

Main point — prove “major” status with metrics and evidence.

Publication in an exhibition catalogue/book?

Weak evidence for the media criterion. Catalogs:

  • Not major media
  • Limited audience
  • Better for Contributions or Exhibitions criteria

Outlet sold on Upwork for $300 — use it?

Risky. If an outlet is known to sell publications:

  • Officer may be aware
  • Publication quality is low
  • Choose another outlet

A book — does it count for media criterion?

No. A book is:

  • Your authored work
  • Not “published material about you”
  • Use it for Authorship or Contributions

Specific outlets: experience and reviews

T-Journal (Tinkoff Journal) — does it count?

Yes, if the article is about you:

  • Major Russian outlet (high traffic)
  • Editorial control
  • But your authored articles are not the same as articles about you

Express-Gazeta (eg.ru) — acceptable?

Yes, a good outlet:

  • Federal media with a large audience
  • Successful approval cases exist
  • Support with SimilarWeb traffic data

Detailed review

Success stories: 57 cases

Pravda.ru — acceptable?

Yes, acceptable:

  • Known Russian outlet
  • Good history and recognition
  • Provide traffic data

Argumenti Nedeli — acceptable?

Yes, a good outlet:

  • Federal weekly newspaper
  • Print circulation + online
  • Successful approvals exist

Argumenti Nedeli — docs to prove major status

Documents to prove AN major status
Document What it proves
Roskomnadzor license Official status in the Russian media market
Medialogia 2025 #9 among the most-cited federal newspapers in Russia
Audience data 7M audience, 3+M readers
“Golden Pen of Russia” Editor-in-chief awarded prestigious journalism prize
Union of Journalists award Editor-in-chief honored for editorial column
“Litera-2022” Journalist from the outlet won a regional prize
Traffic Report 1.36M visits per month

Why this works: Journalistic awards + Medialogia ranking + 17 years of history + partnerships with KP.

TAdviser — good for IT?

Yes, strong industry outlet:

  • Major portal about IT in Russia
  • Professional audience (CIOs, IT directors)
  • Editorial control — not self-published
  • Excellent as a professional/trade publication

MSN.com — acceptable for O-1/EB-1A?

Depends on the origin:

  • Original MSN content — yes
  • Reposts — cite the original
  • MSN is an aggregator — the primary source is what matters

Dni.ru — acceptable?

A mid-level outlet:

  • Use in combination with other media
  • Support with traffic data
  • Combine with stronger sources

Where to get help with publications

Russian and international PR

Olga Maraeva — PR specialist, helps with placements in Russian and international media. Dozens of successful community cases.

Irina Golmgrey — media strategy expert, consults on publication strategy and helps with placements. Many positive reviews from members.

Ukrainian media

Daniil from Publishare Agency — specializes in Ukrainian media for O-1/EB-1. Partnered with 1,500+ Ukrainian outlets, 200+ clients since 2017.

Important

Before ordering paid placements, ensure you understand USCIS requirements for articles. Even paid placement in a major outlet can be rejected if it does not meet criteria.

Frequently Asked Questions (FAQ)

How many media publications are needed for EB-1A?

There is no minimum. One strong article in a major media outlet can be sufficient. Outlet quality and article content matter more.

Do online outlets count as major media?

Yes, if the outlet has a significant audience. USCIS examines SimilarWeb and similar metrics to assess scale.

Do publications need to be translated into English?

Yes, all non-English documents must have certified English translations.

Related articles: USA, immigration and job search

:newspaper: Publications in Media -
Request For Evidence (RFE) Denial Database. When USCIS says “no” -
Officer 0413 -
:memo: Scholarly Articles -
:memo: Scholarly Articles -
:chequered_flag: Final Merits

When I helped a friend put together her case, the media part took the most time — not because there weren’t any publications, but because proving that a publication was “major” turned into a whole ordeal. It’s good that RFE is covered here too, because they often ask for additional documents specifically on that criterion. Don’t leave gathering circulation figures until later — that’s what causes the most stress.

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Oh yeah, circulation figures are a whole separate pain. When I was preparing my documents I thought, what could be so hard — I found an article and attached it. But then it turned out you also have to prove that the publication itself is significant, and SimilarWeb no longer counts as an argument. If you have publications not in English, start the translations early — it always takes longer than it seems.

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One more point people often miss — the subject of the publication should be about you and your work, not an article you wrote. People confuse authored articles (that’s scholarly, a different criterion) and published material about the beneficiary. If you wrote a column in Forbes yourself that’s one thing; if someone wrote about you and your project, that’s what counts here. In practice officers look at this closely, especially after an RFE. And yes, regarding format — a YouTube video is theoretically possible, but you have to build a full argument that it’s major media; you can’t just drop a link.

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By the way, for anyone preparing without an attorney — I highly recommend reading real denials in your field on the USCIS website; you can see what people are tripping up on. Lawyers often say “you have everything ready,” and then an RFE arrives about exactly what they didn’t check. How many publications are needed and in which specific outlets depends on the case; there’s no universal number, though…

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Regarding publication requirements — it really depends on the lawyer and the case. Some demand at least six authored articles plus four interviews; others manage with fewer pieces but in much larger outlets. The outlet’s reach actually matters: if it has fewer than half a million readers a month they may nitpick that it’s not a major media outlet. If I were you, I wouldn’t chase quantity but focus on how it looks as a whole — one strong placement in a top industry outlet is better than five in unknown blogs that you’ll then have to prove are significant. And the main point: don’t confuse the two criteria — interviews about you belong in one category, and your expert pieces are scholarly articles; they’re different things, though lawyers sometimes mix them up.

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So the difference between “you wrote” and “they wrote about you” - it’s really a trap, many stumble over it. A friend also thought her op-ed would work, but it turned out the criteria were completely different. Better to figure it out right away than to redo it later in a panic )

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listen — and for those doing it themselves: read the denials on the USCIS website for your field; you can clearly see what people are failing on. lawyers often say “yeah, everything’s already ready for you”, but in reality you need to do a deep analysis, especially for media. how many articles you need and in which publications is case-by-case — there’s no universal number )

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