Contract analysis

I. Purpose and Scope This memorandum documents the results of supervised recruitment campaigns conducted pursuant to 20 C.F.R. § 656.17 for four PERM labor certification applications filed on behalf of Lumos Analytics Inc. (hereinafter referred to as the "Employer" or "Lumos"). Calderwood & Harkness LLP, as immigration counsel to the Employer, supervised and directed all aspects of the recruitment campaigns described

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

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

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

4. Director, Information Security & Compliance — Beneficiary: Yumiko Tanaka The Employer, Lumos Analytics Inc., is a Delaware C-Corporation headquartered in Palo Alto, California. Lumos is an enterprise software-as-a-service ("SaaS") and financial technology ("fintech") company specializing in artificial intelligence-driven credit risk analytics and automated underwriting solutions for financial institutions. As of t

II. Summary of Recruitment Steps Completed A. Overview of Regulatory Requirements The regulations governing the PERM labor certification process, codified at 20 C.F.R. § 656.17(e), establish mandatory recruitment steps that an employer must complete before filing a PERM application for a professional occupation. A professional occupation is defined under the regulations as any occupation for which the minimum educati

III. Position-Specific Minimum Requirements This section sets forth the minimum requirements established by the Employer for each of the four positions, including the applicable Standard Occupational Classification ("SOC") code, prevailing wage determination, offered salary, minimum education and experience requirements, and any special skills or requirements. The minimum requirements for each position were establish

IV. Detailed Recruitment Results — Position by Position This section sets forth the detailed results of the recruitment campaigns for each of the four positions, including the total number of resumes and applications received, the disposition of each applicant, and the lawful, job-related reasons for the rejection or non-hire of each applicant. All applicants were evaluated solely against the minimum requirements est

1. Summary Statistics • Total resumes/applications received: 14 • Applicants meeting all minimum requirements: 0 • Qualified, willing, and available U.S. workers identified: 0

2. Applicant-by-Applicant Disposition The following is a detailed account of the disposition of each of the 14 applicants who responded to the Employer's recruitment efforts for the Vice President, Engineering — Core Platform position: Applicants 1 through 6 (six applicants): These six applicants did not meet the minimum education requirement for the position. The resumes of all six applicants were carefully reviewed

3. Conclusion — Mehta Position Good-faith recruitment was conducted for the Vice President, Engineering — Core Platform position using all mandatory recruitment steps and three additional recruitment steps, as required by 20 C.F.R. § 656.17(e). All 14 applicants who responded to the Employer's recruitment efforts were evaluated against the minimum requirements established for the position. No qualified, willing, and

1. Summary Statistics • Total resumes/applications received: 8 • Applicants meeting all minimum requirements: 0 • Qualified, willing, and available U.S. workers identified: 0

2. Applicant-by-Applicant Disposition The following is a detailed account of the disposition of each of the 8 applicants who responded to the Employer's recruitment efforts for the Senior Director, Data Science & Machine Learning position: Applicants 1 through 4 (four applicants): These four applicants did not hold a Ph.D. in Statistics, Computer Science, or a closely related quantitative field, as required by the mi

3. Conclusion — Varga Position Good-faith recruitment was conducted for the Senior Director, Data Science & Machine Learning position using all mandatory recruitment steps and three additional recruitment steps, as required by 20 C.F.R. § 656.17(e). All 8 applicants who responded to the Employer's recruitment efforts were evaluated against the minimum requirements established for the position. No qualified, willing,

1. Summary Statistics • Total resumes/applications received: 11 • Applicants meeting all minimum requirements: 0 • Qualified, willing, and available U.S. workers identified: 0

2. Applicant-by-Applicant Disposition The following is a detailed account of the disposition of each of the 11 applicants who responded to the Employer's recruitment efforts for the Vice President, Product — Fintech Solutions position: Applicants 1 through 7 (seven applicants): These seven applicants did not meet the minimum experience requirement of five (5) years of progressive experience in fintech product managem

3. Conclusion — Aguilar-Reyes Position Good-faith recruitment was conducted for the Vice President, Product — Fintech Solutions position using all mandatory recruitment steps and three additional recruitment steps, as required by 20 C.F.R. § 656.17(e). All 11 applicants who responded to the Employer's recruitment efforts were evaluated against the minimum requirements established for the position. No qualified, willi

1. Summary Statistics • Total resumes/applications received: 9 • Applicants meeting all minimum requirements: 0 • Qualified, willing, and available U.S. workers identified: 0

2. Applicant-by-Applicant Disposition The following is a detailed account of the disposition of each of the 9 applicants who responded to the Employer's recruitment efforts for the Director, Information Security & Compliance position: Applicants 1 through 5 (five applicants): These five applicants did not hold a Master's degree in Cybersecurity, Information Systems, or a closely related field, as required by the mini

3. Conclusion — Tanaka Position Good-faith recruitment was conducted for the Director, Information Security & Compliance position using all mandatory recruitment steps and three additional recruitment steps, as required by 20 C.F.R. § 656.17(e). All 9 applicants who responded to the Employer's recruitment efforts were evaluated against the minimum requirements established for the position. No qualified, willing, and

V. Consolidated Summary Table The following table summarizes the recruitment results for all four positions: Across all four positions, the Employer received a combined total of 42 resumes and applications in response to the supervised recruitment campaigns. Of these 42 applicants, zero (0) were found to be qualified, willing, and available U.S. workers for any of the four positions. Each applicant was evaluated indi

VI. Certification and Conclusion Based on the foregoing, Calderwood & Harkness LLP, as immigration counsel to Lumos Analytics Inc., hereby certifies and concludes as follows: Good-Faith Recruitment. All recruitment for each of the four positions identified in this report was conducted in good faith and in strict compliance with the requirements of 20 C.F.R. § 656.17, including the mandatory recruitment steps set fort

VII. Signature block CALDERWOOD & HARKNESS LLP By: ________ Name: Derek Okonkwo Title: Lead Associate Date: December 11, 2023 By: ________ Name: Tiffany Rosenthal Title: Associate Date: December 11, 2023 555 California Street, 32nd Floor San Francisco, California 94104 Telephone: (415) 829-7100 Matter No.: 1008-00004 Appendix References The following appendices are referenced in this report and are maintained in the