Contract analysis

I. Purpose and Summary This memorandum provides a comprehensive pre-filing substantive analysis of the four ETA Form 9089 PERM labor certification applications to be filed on behalf of Lumos Analytics Inc. (the "Employer" or "Lumos"), the petitioning employer, 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 positions are located at the Lumos corporate headquarters at 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303. The job opportunities are full-time, permanent positions, and none involves a staffing or contracting arrangement. Employer Background. Lumos Analytics Inc. is a Delaware C-Corporation, Employer Identification Number (EIN) 84

II. Filing Schedule and Case Numbers The four PERM applications are organized into two filing batches, as summarized below: Batch 1 — Filing Date: December 18, 2023 Batch 2 — Filing Date: January 8, 2024 All four applications will be filed electronically through the Department of Labor's Foreign Labor Application Gateway ("FLAG") system and will be processed by the Atlanta National Processing Center. Based on current

III. Beneficiary 1 — Rajan Mehta (VP, Engineering — Core Platform)

III.A. Position Overview and SOC Classification Job Title: Vice President, Engineering — Core Platform SOC Code: 15-1252 (Software Developers) Worksite: 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303 Employment Type: Full-time, permanent position. This is a direct-hire position within Lumos Analytics Inc. The position is not a staffing, outsourcing, or contracting arrangement, and the beneficiary will p

III.B. Actual Minimum Requirements Analysis (Section H) The actual minimum requirements for the VP, Engineering — Core Platform position at Lumos Analytics Inc. are as follows: Minimum Education: Master's degree in Computer Science or a closely related field. Minimum Experience: Five (5) years of progressive post-baccalaureate experience in software engineering, including at least two (2) years of experience specific

III.C. EB-2 Classification Confirmation Classification: EB-2, Advanced Degree Professional, under INA § 203(b)(2) and 8 C.F.R. § 204.5(k)(2). Rajan Mehta holds the following academic credentials: • M.S., Computer Science — Indian Institute of Technology Bombay (IIT Bombay), Mumbai, India (conferred 2014) • B.Tech, Computer Science — National Institute of Technology Tiruchirappalli (NIT Trichy), India (conferred 2012)

III.D. Offered Wage vs. Prevailing Wage Comparison The prevailing wage determination ("PWD") for this position was received from the DOL National Prevailing Wage Center on September 8, 2023. The details are as follows: The offered salary of $285,000 per year materially exceeds the prevailing wage of $198,744 per year. The prevailing wage requirement is satisfied. It should be noted that the Level IV designation refle

III.E. Section H (Job Opportunity) — Key Responses Review The following summarizes the key substantive responses to be entered in Section H of the Form 9089 for the Mehta application: Employer Information: Lumos Analytics Inc., 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303. Employer Identification Number: 84-3291057. NAICS Code: 511210 (Software Publishers), which is the appropriate classification for

III.F. Section J (Beneficiary Qualifications) — Alignment This subsection confirms that Rajan Mehta's qualifications meet or exceed all stated minimum requirements for the VP, Engineering — Core Platform position. Education: Mr. Mehta holds an M.S. in Computer Science from IIT Bombay (2014) and a B.Tech in Computer Science from NIT Trichy (2012). The M.S. in Computer Science directly satisfies the minimum educational

IV. Beneficiary 2 — Lina Varga (Senior Director, Data Science & Machine Learning)

IV.A. Position Overview and SOC Classification Job Title: Senior Director, Data Science & Machine Learning SOC Code: 15-2051 (Data Scientists) Worksite: 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303 Employment Type: Full-time, permanent position. This is a direct-hire role within Lumos Analytics Inc. The position does not involve staffing, outsourcing, or contract labor arrangements. All duties will be

IV.B. Actual Minimum Requirements Analysis (Section H) The actual minimum requirements for the Senior Director, Data Science & Machine Learning position at Lumos Analytics Inc. are as follows: Minimum Education: Ph.D. in Statistics, Computer Science, or a closely related quantitative field. Minimum Experience: Three (3) years of post-doctoral experience in applied machine learning, including at least two (2) years of

IV.C. EB-2 Classification Confirmation Classification: EB-2, Advanced Degree Professional, under INA § 203(b)(2) and 8 C.F.R. § 204.5(k)(2). Lina Varga holds the following academic credentials: • Ph.D., Statistics — ETH Glenrock Assurance (Eidgenössische Technische Hochschule Zürich), Glenrock Assurance, Switzerland (conferred 2016) • M.Sc., Applied Mathematics — Eötvös Loránd University (ELTE), Budapest, Hungary (co

IV.D. Offered Wage vs. Prevailing Wage Comparison The prevailing wage determination for this position was received from the DOL National Prevailing Wage Center on September 11, 2023. The details are as follows: The offered salary of $310,000 per year substantially exceeds the prevailing wage of $191,360 per year, representing a margin of 62.0% above the PWD. The prevailing wage requirement is amply satisfied. The Lev

IV.E. Section H (Job Opportunity) — Key Responses Review The following summarizes the key substantive responses for Section H of the Varga application: Employer Information: Lumos Analytics Inc., 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303. EIN: 84-3291057. NAICS Code: 511210 (Software Publishers). Employer information is identical to the Mehta application. Union Bargaining Unit: Not applicable. The

IV.F. Section J (Beneficiary Qualifications) — Alignment This subsection confirms that Lina Varga's qualifications meet or exceed all stated minimum requirements. Education: Dr. Varga holds a Ph.D. in Statistics from ETH Glenrock Assurance (2016) and an M.Sc. in Applied Mathematics from Eötvös Loránd University (2012). The Ph.D. in Statistics directly satisfies the minimum educational requirement of a Ph.D. in Statis

V. Beneficiary 3 — Tomás Aguilar-Reyes (VP, Product — Fintech Solutions)

V.A. Position Overview and SOC Classification Job Title: Vice President, Product — Fintech Solutions SOC Code: 11-2021 (Marketing Managers) A Note on SOC Classification. Product management roles do not have a dedicated Standard Occupational Classification code within the DOL's occupational taxonomy. The SOC code 11-2021 (Marketing Managers) is the most commonly accepted and widely used classification for senior produ

V.B. Actual Minimum Requirements Analysis (Section H) The actual minimum requirements for the VP, Product — Fintech Solutions position at Lumos Analytics Inc. are as follows: Minimum Education: Master's degree in Business Administration, Finance, or a closely related field. Minimum Experience: Five (5) years of progressive experience in fintech product management, including at least three (3) years of experience mana

V.C. EB-2 Classification Confirmation Classification: EB-2, Advanced Degree Professional, under INA § 203(b)(2) and 8 C.F.R. § 204.5(k)(2). Tomás Aguilar-Reyes holds the following academic credentials: • MBA — IPADE Business School, Mexico City, Mexico (conferred 2013) • B.S., Industrial Engineering — Tecnológico de Monterrey (ITESM), Monterrey, Mexico (conferred 2010) The position requires a Master's degree in Busin

V.D. Offered Wage vs. Prevailing Wage Comparison The prevailing wage determination for this position was received from the DOL National Prevailing Wage Center on October 2, 2023. The details are as follows: The offered salary of $275,000 per year significantly exceeds the prevailing wage of $176,842 per year. The prevailing wage requirement is satisfied. The Level III wage level designation reflects the position's re

V.E. Section H (Job Opportunity) — Key Responses Review The following summarizes the key substantive responses for Section H of the Aguilar-Reyes application: Employer Information: Lumos Analytics Inc., 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303. EIN: 84-3291057. NAICS Code: 511210 (Software Publishers). Employer information is consistent across all four applications. Union Bargaining Unit: Not appl

V.F. Section J (Beneficiary Qualifications) — Alignment This subsection confirms that Tomás Aguilar-Reyes's qualifications meet or exceed all stated minimum requirements. Education: Mr. Aguilar-Reyes holds an MBA from IPADE Business School (2013) and a B.S. in Industrial Engineering from Tecnológico de Monterrey (2010). The MBA directly satisfies the minimum educational requirement of a Master's degree in Business Ad

VI. Beneficiary 4 — Yumiko Tanaka (Director, Information Security & Compliance)

VI.A. Position Overview and SOC Classification Job Title: Director, Information Security & Compliance SOC Code: 15-1212 (Information Security Analysts) Worksite: 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303 Employment Type: Full-time, permanent position. This is a direct-hire role within Lumos Analytics Inc. The position does not involve staffing, outsourcing, or contract labor arrangements. All dutie

VI.B. Actual Minimum Requirements Analysis (Section H) The actual minimum requirements for the Director, Information Security & Compliance position at Lumos Analytics Inc. are as follows: Minimum Education: Master's degree in Cybersecurity, Information Systems, or a closely related field. Minimum Experience: Four (4) years of progressive experience in information security, including at least two (2) years of experien

VI.C. EB-2 Classification Confirmation Classification: EB-2, Advanced Degree Professional, under INA § 203(b)(2) and 8 C.F.R. § 204.5(k)(2). Yumiko Tanaka holds the following academic credentials: • M.S., Cybersecurity — Carnegie Mellon University, Pittsburgh, Pennsylvania (conferred 2017) • B.Eng., Information Engineering — University of Tokyo, Tokyo, Japan (conferred 2015) The position requires, at minimum, a Maste

VI.D. Offered Wage vs. Prevailing Wage Comparison The prevailing wage determination for this position was received from the DOL National Prevailing Wage Center on October 2, 2023. The details are as follows: The offered salary of $260,000 per year comfortably exceeds the prevailing wage of $185,910 per year. The prevailing wage requirement is satisfied. The Level IV designation appropriately reflects the director-lev

VI.E. Section H (Job Opportunity) — Key Responses Review The following summarizes the key substantive responses for Section H of the Tanaka application: Employer Information: Lumos Analytics Inc., 2240 Embarcadero Way, Suite 600, Palo Alto, California 94303. EIN: 84-3291057. NAICS Code: 511210 (Software Publishers). Employer information is consistent across all four applications. Union Bargaining Unit: Not applicable

VI.F. Section J (Beneficiary Qualifications) — Alignment This subsection confirms that Yumiko Tanaka's qualifications meet or exceed all stated minimum requirements. Education: Ms. Tanaka holds an M.S. in Cybersecurity from Carnegie Mellon University (2017) and a B.Eng. in Information Engineering from the University of Tokyo (2015). The M.S. in Cybersecurity directly satisfies the minimum educational requirement of a

VII. Cross-Cutting Compliance Considerations The following compliance considerations apply across all four PERM applications and are addressed here to avoid redundancy in the individual beneficiary analyses.

VII.A. Employer Attestations Under 20 C.F.R. § 656 Under the PERM regulations at 20 C.F.R. § 656, the petitioning employer must make a series of attestations in connection with each ETA Form 9089 filing. The following attestations are applicable to all four applications and have been reviewed with Lumos's General Counsel, Marcus Whitfield, and HR Manager, Janelle Kwon: (1) Bona Fide Job Opportunity. Lumos attests tha