Contract analysis

I. Purpose and Executive Summary The purpose of this memorandum is to confirm the successful completion of all four PERM labor certification and EB-2 (Employment-Based Second Preference — Advanced Degree Professional) I-140 immigrant visa petition matters undertaken by Calderwood & Harkness LLP on behalf of Lumos Analytics Inc. ("Lumos" or the "Client") for the following four foreign-national beneficiaries:

1. Rajan Mehta — Vice President, Engineering — Core Platform

2. Lina Varga — Senior Director, Data Science & Machine Learning

3. Tomás Aguilar-Reyes — Vice President, Product — Fintech Solutions

4. Yumiko Tanaka — Director, Information Security & Compliance All four I-140 petitions were filed with the USCIS Texas Service Center under Premium Processing and were approved between March 7, 2024, and March 22, 2024. No requests for evidence ("RFEs"), notices of intent to deny ("NOIDs"), or audits were issued by either the U.S. Department of Labor ("DOL") or U.S. Citizenship and Immigration Services ("USCIS") at

II. Client and Matter Background A. Client Profile Lumos Analytics Inc. ("Lumos") is a Delaware C-Corporation headquartered at 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303. Lumos is an enterprise SaaS and fintech company specializing in AI-driven credit risk analytics and automated underwriting platforms. The company's core product offerings leverage proprietary machine learning models to provide real

III. Summary of Case Outcomes — By Beneficiary This section provides a detailed summary of the case outcome for each of the four beneficiaries, including biographical and immigration status information, the EB-2 qualification basis, the prevailing wage determination, the recruitment campaign, the PERM application and certification, the I-140 petition and approval, and the position minimum requirements as filed on the

1. Sunday Newspaper Advertisements: Two advertisements were placed in The Peninsula Gazette, a newspaper of general circulation in the area of intended employment, on Sunday, October 15, 2023, and Sunday, October 22, 2023. The advertisements contained all information required by regulation, including the employer name, a description of the job opportunity, the job location, and instructions for applying. Tear sheets

2. State Workforce Agency (SWA) Job Order: A job order was placed with the California Employment Development Department via the CalJOBS online system, in accordance with 20 CFR § 656.17(e)(1)(i)(B). The job order was active for the required thirty-day posting period.

3. Internal Posting: A notice of the job opportunity was posted internally at Lumos's Palo Alto worksite for a period of ten (10) consecutive business days, in accordance with 20 CFR § 656.10(d). The posting was displayed in a conspicuous location accessible to all employees at the worksite and contained all required information, including the offered wage and a description of how to report alleged violations of the

4. Professional Journal Online Advertisement: An advertisement was placed in FinTech Talent Weekly, published by Creston Media Group, Inc., an online professional trade publication appropriate for the occupation. This advertisement satisfied one of the three additional recruitment steps required under 20 CFR § 656.17(e)(1)(ii) for professional occupations.

5. Campus Posting: The job opportunity was posted through the Baxter University Career Center, satisfying a second additional recruitment step.

6. Employee Referral Program: The position was circulated through Lumos's internal employee referral program, with incentive information included. This constituted the third additional recruitment step. Recruitment Results A total of fourteen (14) resumes were received in response to the recruitment campaign. After a thorough and good-faith review of all applications, zero (0) qualified U.S. workers were identified.

I-140 Petition The Form I-140 Immigrant Petition for Alien Workers was filed with the USCIS Texas Service Center on February 22, 2024, under Premium Processing Service (Form I-907). The petition was assigned Receipt Number SRC-24-901-12340. The filing was directed to the USCIS Texas Service Center, 6046 N Belt Line Road, Irving, TX 75038. The I-140 petition was approved on March 7, 2024, within the fifteen-business-d

I-140 Petition The I-140 petition was filed with the USCIS Texas Service Center on February 22, 2024, under Premium Processing, and was assigned Receipt Number SRC-24-901-12345. The petition was approved on March 8, 2024. No request for evidence was issued. Position Minimum Requirements (As Filed on PERM) • Ph.D. in Statistics, Computer Science, or closely related quantitative field; • Three (3) years of post-doctora

I-140 Petition The I-140 petition was filed with the USCIS Texas Service Center on March 8, 2024, under Premium Processing, and was assigned Receipt Number SRC-24-901-15560. The petition was approved on March 22, 2024. No request for evidence was issued. Position Minimum Requirements (As Filed on PERM) • Master's degree in Business Administration, Finance, or closely related field; • Five (5) years of progressive exp

I-140 Petition The I-140 petition was filed with the USCIS Texas Service Center on March 8, 2024, under Premium Processing, and was assigned Receipt Number SRC-24-901-15565. The petition was approved on March 21, 2024. No request for evidence was issued. Position Minimum Requirements (As Filed on PERM) • Master's degree in Cybersecurity, Information Systems, or closely related field; • Four (4) years of progressive e

IV. Consolidated Case Status Table The following table provides a consolidated summary of the case outcomes for all four beneficiaries: All four PERM applications were certified without audit, and all four I-140 petitions were approved without a request for evidence. No appeal, motion to reopen, or motion to reconsider was required in connection with any of the four cases.

V. Financial Summary A. Fee Structure Recap The engagement was structured on a flat-fee basis, as set forth in the engagement letter dated June 12, 2023. The fee arrangement was as follows: • Flat fee per beneficiary: $12,500, covering all attorney time and work product associated with the preparation and filing of the PERM labor certification application (ETA Form 9089) and the I-140 immigrant visa petition for each

VI. Next Steps for Each Beneficiary — Adjustment of Status / Consular Processing The approval of the I-140 petitions represents the completion of the second of three principal stages in the employment-based green card process. The remaining stage — the actual application for lawful permanent resident status — requires either the filing of a Form I-485 (Application to Register Permanent Residence or Adjust Status) wit

1. H-1B Extensions under AC21 § 106(a): Plan for the first one-year H-1B extension to be filed in advance of the September 14, 2025, expiration date. The firm should calendar this deadline and propose a new engagement for the H-1B extension filing no later than spring 2025.

2. EB-1 Reclassification Strategy: The firm should evaluate whether Mr. Mehta's qualifications — including his leadership of a 45-person engineering team, his role in architecting a platform processing 100M+ daily transactions, and any publications, patents, industry recognition, or other distinguishing achievements — may support a petition under the EB-1A (Extraordinary Ability) or EB-1B (Outstanding Professor or Re

3. I-485 Filing: Not available until Mr. Mehta's EB-2 India priority date becomes current per the visa bulletin. The firm should monitor the visa bulletin on a monthly basis and advise the client promptly when filing becomes available. B. Lina Varga (Hungary — EB-2) Priority Date: December 18, 2023 Hungary is classified under the "All Chargeability Areas Except Those Listed" (commonly referred to as "rest of world")

1. I-485 Filing Before L-1A Expiration: If Mr. Aguilar-Reyes's priority date is current (or becomes current under the "Dates for Filing" chart, which USCIS may accept for I-485 filing eligibility), the I-485 application should be filed before the July 30, 2024, L-1A expiration date. Once the I-485 is filed and pending, Mr. Aguilar-Reyes will be in a period of authorized stay for the duration of the I-485 pendency, re

2. H-1B Cap-Exempt Petition: As the beneficiary of an approved I-140 petition, Mr. Aguilar-Reyes is eligible for an H-1B petition that is exempt from the annual H-1B cap. Lumos could file an H-1B cap-exempt change of status petition on Mr. Aguilar-Reyes's behalf to bridge the gap between the L-1A expiration and the eventual adjudication of an I-485 application, or as a long-term status solution if the EB-2 Mexico pri

3. Combination Strategy: If timing permits, the most prudent approach may be to file both an I-485 application (if the priority date is current) and an H-1B cap-exempt petition simultaneously, providing maximum flexibility and status protection. Recommendation: Calderwood & Harkness LLP should initiate immediate outreach to Marcus Whitfield and Janelle Kwon at Lumos regarding Mr. Aguilar-Reyes's status planning. This

1. I-485 adjustment of status filings (with concurrent I-765 EAD and I-131 Advance Parole applications) for Lina Varga, Tomás Aguilar-Reyes (if priority date is current), and Yumiko Tanaka;

2. H-1B cap-exempt change of status petition for Tomás Aguilar-Reyes, as an alternative or complementary filing to address the L-1A expiration on July 30, 2024;

3. Status maintenance planning for Rajan Mehta, including H-1B extension strategy under AC21 § 106(a) and evaluation of EB-1 reclassification feasibility; and

4. Ongoing Visa bulletin monitoring for all four beneficiaries. The outreach letter should emphasize the particular urgency of the Aguilar-Reyes matter given the L-1A expiration date of July 30, 2024. Delay in addressing this issue could result in a lapse of Mr. Aguilar-Reyes's authorized status, which would have serious consequences for his ability to remain and work in the United States. Additionally, if any benefi

VII. Matter Timeline Summary The following is a chronological summary of the key milestones achieved during the course of this engagement:

VIII. File Retention and PERM Audit Compliance A. DOL Regulatory Requirements Under 20 CFR § 656.10(f) and related regulations, the employer filing a PERM labor certification application is required to maintain documentation sufficient to establish compliance with the requirements of 20 CFR Part 656 for a period of five (5) years from the date of filing of the ETA Form 9089 application, or from the date on which the

IX. Acknowledgments and Distribution This memorandum is distributed internally to the following members of the Calderwood & Harkness LLP matter team: • Colette Whitman, Partner (Bankruptcy & Restructuring Practice Group) — Responsible Partner • Elaine Forsythe, Partner (Antitrust & Competition Practice Group) — Billing Partner • Tiffany Rosenthal, Associate — Working Associate (for information) A separate client noti

X. Signature block Prepared by: ________________________________________ Derek Okonkwo Associate Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104 Date: April 30, 2024 Reviewed and Approved by: ________________________________________ Colette Whitman Partner Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104 Date: April 30, 2024 This memorandum is pro