Contract analysis

I. Introduction and Purpose of Filing This firm, Calderwood & Harkness LLP, serves as immigration counsel of record to Lumos Analytics Inc. ("Lumos," the "Company," or "Petitioner") in connection with the above-referenced petition and all related immigration matters. We submit this cover letter together with the enclosed Form I-140, Immigrant Petition for Alien Worker, filed on behalf of Lumos Analytics Inc. for the

II. Petitioner Information Lumos Analytics Inc. is the petitioning employer and sponsor of the instant I-140 petition. The following information is provided regarding the Petitioner: Full Legal Name: Lumos Analytics Inc. Entity Type: C-Corporation, incorporated under the laws of the State of Delaware and qualified to do business in the State of California. Employer Identification Number (EIN): 84-3291057 Principal Of

III. Beneficiary Information The following information is provided regarding the Beneficiary, Rajan Mehta: Full Legal Name: Rajan Mehta Country of Citizenship: India Current Immigration Status: H-1B Nonimmigrant (Specialty Occupation Worker), valid through September 14, 2025 Position Offered: Vice President, Engineering — Core Platform Offered Annual Salary: $285,000.00 Worksite Location: 2240 Embarcadero Way, Suite

IV. PERM Labor Certification Summary The instant I-140 petition is supported by an approved permanent labor certification application, as required for EB-2 petitions filed under the labor certification pathway. The relevant PERM details are as follows: Filing Date: December 18, 2023 PERM Case Number: A-23401-83756 Date Certified: February 14, 2024 Certifying Office: U.S. Department of Labor, Employment and Training A

V. Position Requirements and Beneficiary Qualifications The proffered position of Vice President, Engineering — Core Platform, as described in the certified PERM labor certification and the employer support letter, carries the following minimum requirements: Minimum Education: Master's degree in Computer Science or a closely related field. Minimum Experience: Five (5) years of progressive post-baccalaureate experienc

VI. Ability to Pay the Offered Wage Lumos Analytics Inc. has the financial ability to pay the offered wage of $285,000.00 per year to Mr. Mehta from the priority date of December 18, 2023, and continuing until the Beneficiary obtains lawful permanent resident status, as required by 8 C.F.R. §204.5(g)(2). The Petitioner's ability to pay the proffered wage is demonstrated by the following:

1. Annual Revenue. Lumos Analytics Inc. reported annual revenue of $87.4 million for fiscal year 2023. This substantial revenue base reflects the Company's strong market position and its capacity to sustain its current workforce, including the Beneficiary's offered salary.

2. Workforce Size. As of June 30, 2023, Lumos employed 312 full-time employees, reflecting a substantial and growing workforce that the Company has been able to support financially on an ongoing basis.

3. Financial Documentation. The enclosed corporate financial documentation, including the Company's federal tax returns and/or audited financial statements for the relevant tax year, demonstrates that Lumos possesses net income and/or net current assets sufficient to pay the Beneficiary's offered wage. These documents are enclosed at Tab G.

4. Employer Support Letter. The employer support letter, executed by Priya Chandrasekaran, Chief Executive Officer, and Sonia Elliston, Vice President of People Operations, confirms the bona fide nature of the job offer, the terms of employment (including the offered annual salary of $285,000.00), and the Company's financial ability and commitment to pay the offered wage. This letter is enclosed at Tab F. Under the c

VII. Premium Processing Request Form I-907, Request for Premium Processing Service, is enclosed at Tab B, together with the applicable premium processing fee of $2,500.00, payable by check to the U.S. Department of Homeland Security. Lumos Analytics Inc. respectfully requests that USCIS adjudicate this I-140 petition within the premium processing timeframe of fifteen (15) business days from the date of proper filing

VIII. List of Enclosed Documents The following documents are enclosed with this filing, organized by tabbed exhibit for the convenience of the adjudicating officer: Tab A: Form I-140, Immigrant Petition for Alien Worker, with filing fee of $700.00 (check payable to "U.S. Department of Homeland Security") Tab B: Form I-907, Request for Premium Processing Service, with premium processing fee of $2,500.00 (check payable

IX. Conclusion and Request for Approval Based on the foregoing discussion and the enclosed documentary evidence, Lumos Analytics Inc. respectfully requests that USCIS approve the instant Form I-140 petition and classify the Beneficiary, Rajan Mehta, as an EB-2 Advanced Degree Professional under INA §203(b)(2). All statutory and regulatory requirements for approval of this petition have been satisfied:

1. The petition is supported by an approved PERM labor certification (Case No. A-23401-83756), certified by the Department of Labor on February 14, 2024, establishing that no qualified, willing, and available U.S. workers exist for the proffered position;

2. The Beneficiary holds a Master of Science degree in Computer Science from IIT Bombay, qualifying him as an advanced degree professional under INA §203(b)(2) and 8 C.F.R. §204.5(k)(2);

3. The Beneficiary's education and professional experience meet or exceed all requirements set forth in the certified PERM labor certification, including the minimum educational and experiential qualifications and all special requirements;

4. The offered annual salary of $285,000.00 exceeds the certified prevailing wage of $198,744.00 by a margin of $86,256.00 (43.4%); and

5. The Petitioner has demonstrated its ability to pay the offered wage from the priority date forward, as evidenced by its substantial annual revenue, its financial documentation, and the employer support letter. We respectfully request that any correspondence, notices, requests for additional evidence, or other communications relating to this petition be directed to counsel of record at: Derek Okonkwo Calderwood & H