MEMORANDUM

MEMORANDUM
PRIVILEGED & CONFIDENTIAL — ATTORNEY WORK PRODUCT
Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104
April 30, 2024
TO: Colette Whitman, Partner (Bankruptcy & Restructuring Practice Group — Responsible Partner) Elaine Forsythe, Partner (Antitrust & Competition Practice Group — Billing Partner)
FROM: Derek Okonkwo, Associate (Mergers & Acquisitions Practice Group — Lead Associate)
RE: Matter Closing Memorandum — Lumos Analytics Inc. PERM Labor Certification & EB-2 I-140 Immigrant Visa Petition Sponsorship (Four Beneficiaries)
MATTER NUMBER: 1008-00004
CLIENT: Lumos Analytics Inc. 2240 Embarcadero Way, Suite 600 Palo Alto, CA 94303 EIN: 84-3291057
CLIENT CONTACTS: Marcus Whitfield, General Counsel Janelle Kwon, HR Manager — Immigration Contact
MATTER STATUS: Closed — Completed
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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 any stage of the proceedings for any of the four cases. Each PERM labor certification was certified without audit, and each I-140 petition was approved within the fifteen-business-day premium processing adjudication window.
The engagement was formally opened on June 12, 2023, upon execution of the engagement letter by Marcus Whitfield on behalf of Lumos Analytics Inc. The matter is being closed as of the date of this memorandum, April 30, 2024, representing an approximate duration of ten and one-half (10.5) months from engagement opening to matter closure. All substantive immigration milestones were achieved within that period.
Total amounts billed across five invoices over the life of the engagement were $75,140, representing flat legal fees, USCIS filing fees, USCIS premium processing fees, and pass-through recruitment advertising costs. All five invoices have been paid in full, and there is no outstanding balance on this matter.
This memorandum serves the following purposes:
•  Documents the final disposition of each of the four cases, including all relevant case numbers, receipt numbers, filing dates, approval dates, and priority dates;
•  Summarizes the financial history of the engagement, including fee structure, invoicing, and advertising cost allocation;
•  Identifies and recommends next steps for each beneficiary with respect to the subsequent stage of the green card process, namely adjustment of status (Form I-485) or consular processing;
•  Sets forth the firm's and the Client's respective file retention obligations under applicable DOL regulations and firm policy; and
•  Formally records the closure of Matter No. 1008-00004 in the firm's matter management system.
As a key strategic recommendation, the firm should promptly propose a new engagement to Lumos for I-485 adjustment of status and/or consular processing filings for the three beneficiaries whose priority dates are current or expected to be current under the applicable visa bulletin categories — namely, Varga, Aguilar-Reyes, and Tanaka. This recommendation carries particular urgency with respect to Aguilar-Reyes, whose L-1A nonimmigrant status is set to expire on July 30, 2024. With respect to Mehta, the firm should advise Lumos regarding a long-term status maintenance strategy, including H-1B extensions beyond the sixth year under American Competitiveness in the Twenty-First Century Act ("AC21") § 106(a), and should evaluate the feasibility of an EB-1 reclassification strategy to circumvent the significant India EB-2 visa bulletin backlog.
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-time credit decisioning, portfolio risk monitoring, and regulatory compliance automation for mid-market and enterprise financial institutions across the United States and select international markets.
Lumos was founded in 2019 and has experienced rapid growth since inception. For fiscal year 2023, the company reported annual revenue of approximately $87.4 million. As of June 2023, when this engagement was initiated, Lumos employed approximately 312 full-time employees, with the majority of its technical workforce based at the Palo Alto headquarters and a smaller engineering office in Austin, Texas.
Lumos's principal private equity sponsor is Ridgeline Equity Partners, LP, which served as the lead investor in the company's Series B funding round and holds an approximately 38.2% equity stake in the company. Ridgeline's involvement has been a significant driver of Lumos's headcount growth and strategic expansion, including the recruitment of the four senior foreign-national executives who are the subjects of this engagement.
Lumos's Delaware registered agent is Keystone Registered Agents LLC, located at 850 New Burton Road, Suite 201, Dover, Delaware 19904. The company's general counsel is Marcus Whitfield, who served as the primary client contact for this engagement. Day-to-day immigration coordination was handled by Janelle Kwon, HR Manager, who served as the designated immigration contact and was responsible for supplying corporate documentation, coordinating beneficiary information gathering, and executing employer attestations on filed forms.
B. Engagement Scope
The scope of this engagement encompassed the preparation and filing of PERM labor certification applications (ETA Form 9089) and EB-2 I-140 immigrant visa petitions for four foreign-national executives identified by Lumos as critical to the company's growth strategy and long-term operational leadership. Each of the four beneficiaries held a position requiring an advanced degree and possessed qualifications that supported classification under the EB-2 (Advanced Degree Professional) immigrant visa preference category.
The engagement was limited to the PERM and I-140 stages of the employment-based green card process. The subsequent stage — adjustment of status (Form I-485) within the United States or consular processing at a U.S. embassy or consulate abroad — was expressly excluded from the scope of this engagement, as set forth in the engagement letter dated June 12, 2023. Recommendations regarding next steps for I-485 filing and status maintenance are addressed in Section VI of this memorandum.
C. Staffing
The matter was staffed as follows:
•  Colette Whitman, Partner — Responsible Partner. Ms. Whitman provided overall matter supervision and reviewed all filed applications and petitions prior to submission. Ms. Whitman also participated in the initial client meeting on June 8, 2023, at which the engagement scope and strategy were discussed with Marcus Whitfield and Janelle Kwon.
•  Elaine Forsythe, Partner — Billing Partner. Ms. Forsythe served as the billing partner for this engagement in accordance with the firm's cross-practice staffing protocols. Ms. Forsythe approved all invoices and oversaw billing compliance throughout the engagement.
•  Derek Okonkwo, Associate — Lead Associate. Mr. Okonkwo served as the primary drafter and filer for all four PERM applications and I-140 petitions. Mr. Okonkwo was the day-to-day contact for the client and coordinated all aspects of case strategy, document preparation, recruitment campaign oversight, filing logistics, and government correspondence. Mr. Okonkwo is the author of this closing memorandum.
•  Tiffany Rosenthal, Associate — Working Associate. Ms. Rosenthal assisted with recruitment campaign supervision and compliance, including coordination with the external recruitment advertising vendor, review of recruitment results and applicant dispositions, and prevailing wage research and analysis. Ms. Rosenthal prepared the recruitment reports for all four PERM applications.
D. External Vendors Coordinated
The following external vendors were engaged and coordinated by Calderwood & Harkness LLP in connection with this matter:
•  Broadgate Compliance Services LLC — PERM recruitment advertising vendor and compliance consultant. Contact: Gerald Fitzmorris, Principal. Address: 1414 K Street NW, Suite 730, Washington, DC 20005. Broadgate coordinated the placement of newspaper advertisements, online professional journal advertisements, and other required recruitment steps, and provided compliance documentation and proof-of-publication materials for the PERM audit files.
•  The Peninsula Gazette — Newspaper of general circulation in the Palo Alto / San Jose metropolitan area, used for the mandatory Sunday print newspaper advertisements required under 20 CFR § 656.17(e)(1)(i)(A). Contact: Noreen Caswell, Advertising Representative. Address: 780 Hamilton Avenue, Palo Alto, CA 94301. Two Sunday insertion dates were used for each position, in accordance with DOL requirements.
•  Creston Media Group, Inc. — Publisher of FinTech Talent Weekly, a professional or trade journal within the meaning of 20 CFR § 656.17(e)(1)(i)(B), used for online professional journal advertisements as one of the three additional recruitment steps required for professional occupations. Address: 41 East 11th Street, 5th Floor, New York, NY 10003.
•  Baxter University Career Center — Used for campus posting as an additional recruitment step under 20 CFR § 656.17(e)(1)(ii). Baxter University's career center agreed to post the job opportunity notices for all four positions on its online job board accessible to current students and alumni.
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 PERM application. Each subsection constitutes a comprehensive record of the case for file retention and future reference purposes.
A. Beneficiary 1: Rajan Mehta — Vice President, Engineering — Core Platform
Biographical and Immigration Information
Mr. Rajan Mehta is a citizen and national of India. At the time this engagement was initiated, Mr. Mehta held H-1B nonimmigrant status, with a validity period extending through September 14, 2025. Mr. Mehta has been employed by Lumos Analytics Inc. since August 2020 and was promoted to the position of Vice President, Engineering — Core Platform in January 2022. In this role, Mr. Mehta leads a team of approximately 45 software engineers responsible for the architecture, development, and operational reliability of Lumos's core distributed computing platform, which processes in excess of 100 million daily credit risk transactions.
EB-2 Qualification Basis
Mr. Mehta qualifies for EB-2 classification as an Advanced Degree Professional. He holds a Master of Science (M.S.) in Computer Science from the Indian Institute of Technology Bombay, conferred in 2014, and a Bachelor of Technology (B.Tech) in Computer Science from the National Institute of Technology Trichy, conferred in 2012. His advanced degree, combined with his extensive post-baccalaureate progressive experience in software engineering and distributed systems architecture, supports his classification under the EB-2 preference category.
SOC Code and Offered Salary
The position was classified under SOC Code 15-1252 (Software Developers), which was determined to be the most appropriate occupational classification for the offered position based on the duties described in the job description and the DOL's Standard Occupational Classification system. The offered annual salary for the position is $285,000.
Prevailing Wage Determination
The prevailing wage determination ("PWD") request was filed with the DOL's National Prevailing Wage Center ("NPWC") on June 26, 2023. The PWD was received on September 8, 2023, and determined the prevailing wage for the position at Level IV (fully competent) to be $198,744 per year, based on the San Jose-Sunnyvale-Santa Clara, California Metropolitan Statistical Area (OES Area Code 41940). The offered salary of $285,000 exceeds the prevailing wage determination by $86,256, representing a margin of approximately 43.4% above the prevailing wage. The PWD tracking number and validity period were documented in the case file.
Recruitment Campaign
The supervised recruitment campaign for the Mehta position commenced on October 9, 2023, and concluded on November 20, 2023. The following recruitment steps were conducted in compliance with 20 CFR § 656.17(e):
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 and proofs of publication were obtained and placed in the audit file.
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 terms and conditions of the PERM application.
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. The dispositions of the applicants were as follows:
•  Six (6) applicants lacked the minimum educational requirement of a Master's degree in Computer Science or a closely related field;
•  Five (5) applicants lacked the required experience in distributed systems architecture;
•  Two (2) applicants declined to proceed after learning further details about the position and its requirements; and
•  One (1) applicant was unresponsive to repeated attempts to schedule an interview.
A detailed recruitment report documenting the results of the recruitment campaign, including the basis for the disposition of each applicant, was prepared by Tiffany Rosenthal and is maintained in the PERM audit file.
PERM Application
The PERM labor certification application (ETA Form 9089) for Mr. Mehta was filed electronically with the DOL on December 18, 2023, and was assigned Case Number A-23401-83756. The priority date established by this filing is December 18, 2023. The application was certified by the DOL on February 14, 2024, without audit or request for additional information.
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-day premium processing adjudication period. No request for evidence was issued.
Position Minimum Requirements (As Filed on PERM)
The minimum requirements for the position, as stated on the ETA Form 9089, were as follows:
•  Master's degree in Computer Science or closely related field;
•  Five (5) years of progressive post-baccalaureate experience in software engineering, including two (2) years of experience in distributed systems architecture;
•  Experience with Apache Kafka, Kubernetes, and microservices at scale (100M+ daily transactions).
These requirements were established based on the actual minimum requirements for the position as determined by Lumos, were not tailored to Mr. Mehta's specific qualifications, and were consistent with the requirements for similar positions in the industry as documented in the PERM recruitment file.
B. Beneficiary 2: Lina Varga — Senior Director, Data Science & Machine Learning
Biographical and Immigration Information
Dr. Lina Varga is a citizen and national of Hungary. At the time this engagement was initiated, Dr. Varga held H-1B nonimmigrant status, with a validity period extending through March 2, 2026. Dr. Varga joined Lumos Analytics Inc. in March 2020 and has served as Senior Director, Data Science & Machine Learning since September 2021. In this role, she leads Lumos's data science division, overseeing a team of approximately 28 data scientists and machine learning engineers responsible for developing and refining the proprietary machine learning models that underpin Lumos's credit risk analytics platform.
EB-2 Qualification Basis
Dr. Varga qualifies for EB-2 classification as an Advanced Degree Professional. She holds a Doctor of Philosophy (Ph.D.) in Statistics from ETH Glenrock Assurance (Swiss Federal Institute of Technology Glenrock Assurance), conferred in 2016, and a Master of Science (M.Sc.) in Applied Mathematics from Eötvös Loránd University (Budapest, Hungary), conferred in 2012. Her doctoral-level education, combined with her post-doctoral research and industry experience in applied machine learning for financial services, provides a strong basis for EB-2 classification.
SOC Code and Offered Salary
The position was classified under SOC Code 15-2051 (Data Scientists). The offered annual salary for the position is $310,000.
Prevailing Wage Determination
The PWD request was filed with the NPWC on June 26, 2023. The PWD was received on September 11, 2023, and established the prevailing wage at Level IV (fully competent) at $191,360 per year for the applicable metropolitan statistical area. The offered salary of $310,000 exceeds the prevailing wage by $118,640, representing a margin of approximately 62.0% above the prevailing wage.
Recruitment Campaign
The supervised recruitment campaign for the Varga position commenced on October 9, 2023, and concluded on November 20, 2023. The recruitment steps undertaken were substantively identical to those described above for Mr. Mehta. Specifically, two Sunday newspaper advertisements were placed in The Peninsula Gazette on October 15 and October 22, 2023; a SWA job order was placed via CalJOBS; a ten-day internal posting was displayed at the Lumos worksite; an online advertisement was placed in FinTech Talent Weekly; a posting was made through the Baxter University Career Center; and the position was circulated through Lumos's employee referral program. All recruitment steps were conducted in full compliance with the regulatory requirements of 20 CFR § 656.17(e).
Recruitment Results
A total of eight (8) resumes were received in response to the recruitment campaign. After a thorough and good-faith review, zero (0) qualified U.S. workers were identified. The dispositions were as follows:
•  Four (4) applicants lacked the minimum educational requirement of a Ph.D. in Statistics, Computer Science, or a closely related quantitative field;
•  Three (3) applicants lacked the required experience in financial services machine learning and credit modeling; and
•  One (1) applicant voluntarily withdrew his or her application prior to further evaluation.
A detailed recruitment report was prepared and is maintained in the PERM audit file.
PERM Application
The PERM application for Dr. Varga was filed on December 18, 2023, and was assigned Case Number A-23401-83761. The priority date is December 18, 2023. The application was certified on February 14, 2024, without audit.
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-doctoral experience in applied machine learning, including two (2) years of experience in financial services credit modeling;
•  Publication record in peer-reviewed journals on statistical learning methods; and
•  Proficiency in Python, R, and TensorFlow.
C. Beneficiary 3: Tomás Aguilar-Reyes — Vice President, Product — Fintech Solutions
Biographical and Immigration Information
Mr. Tomás Aguilar-Reyes is a citizen and national of Mexico. At the time this engagement was initiated, Mr. Aguilar-Reyes held L-1A (Intracompany Transferee — Manager/Executive) nonimmigrant status, with a validity period extending through July 30, 2024. Mr. Aguilar-Reyes was transferred to Lumos Analytics Inc.'s Palo Alto office from a Lumos affiliate entity in Mexico City in August 2021. He has served as Vice President, Product — Fintech Solutions since January 2022. In this capacity, Mr. Aguilar-Reyes leads a cross-functional product management team of approximately 22 members and is responsible for the strategic direction, regulatory compliance, and market launch of Lumos's automated lending and underwriting product suite.
EB-2 Qualification Basis
Mr. Aguilar-Reyes qualifies for EB-2 classification as an Advanced Degree Professional. He holds a Master of Business Administration (MBA) from IPADE Business School (Mexico City), conferred in 2013, and a Bachelor of Science (B.S.) in Industrial Engineering from Tecnológico de Monterrey, conferred in 2010. His MBA, combined with five years of progressive post-baccalaureate experience in fintech product management, supports EB-2 classification.
SOC Code and Offered Salary
The position was classified under SOC Code 11-2021 (Marketing Managers), which was determined to be the closest available DOL Standard Occupational Classification match for a product management leadership role in the fintech sector. While no SOC code exists specifically for "product manager," the duties, skill requirements, and organizational level of the position most closely align with the Marketing Managers classification. The offered annual salary for the position is $275,000.
Prevailing Wage Determination
The PWD request was filed with the NPWC on June 26, 2023. The PWD was received on October 2, 2023, and established the prevailing wage at Level III at $176,842 per year for the applicable area. The offered salary of $275,000 exceeds the prevailing wage by $98,158, representing a margin of approximately 55.5% above the prevailing wage.
Recruitment Campaign
The supervised recruitment campaign for the Aguilar-Reyes position commenced on October 23, 2023, and concluded on December 4, 2023. The recruitment steps were substantively identical to those employed for the first two beneficiaries, with adjusted dates. Two Sunday newspaper advertisements were placed in The Peninsula Gazette on October 29 and November 5, 2023. A SWA job order was placed via CalJOBS; a ten-day internal posting was displayed at the Lumos worksite; an online advertisement was placed in FinTech Talent Weekly; a campus posting was made through the Baxter University Career Center; and the position was circulated through Lumos's employee referral program.
Recruitment Results
A total of eleven (11) resumes were received. After a thorough and good-faith review, zero (0) qualified U.S. workers were identified. The dispositions were as follows:
•  Seven (7) applicants did not meet the minimum experience requirement of five years of progressive experience in fintech product management;
•  Three (3) applicants lacked the required knowledge of fintech regulatory frameworks, including Dodd-Frank and CFPB guidelines as applied to automated lending products; and
•  One (1) applicant accepted another offer of employment before proceeding to the interview stage.
A detailed recruitment report was prepared and is maintained in the PERM audit file.
PERM Application
The PERM application for Mr. Aguilar-Reyes was filed on January 8, 2024, and was assigned Case Number A-24401-00214. The priority date is January 8, 2024. The application was certified on March 1, 2024, without audit.
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 experience in fintech product management, including three (3) years of experience managing cross-functional teams of 15 or more members; and
•  Experience with regulatory frameworks (Dodd-Frank, CFPB guidelines) as applied to automated lending products.
Note Regarding L-1A Status Expiration
Mr. Aguilar-Reyes's L-1A nonimmigrant status was set to expire on July 30, 2024. The I-140 approval on March 22, 2024, was achieved well within the L-1A validity window, providing Mr. Aguilar-Reyes with an approved immigrant visa petition that supports several important avenues for maintaining lawful status and employment authorization. Specifically, the approved I-140 may serve as the basis for filing a cap-exempt H-1B petition (since the beneficiary is the subject of an approved I-140), or for filing an I-485 adjustment of status application if the priority date is current under the applicable visa bulletin category. The urgency of this status planning issue is discussed in further detail in Section VI.C below.
D. Beneficiary 4: Yumiko Tanaka — Director, Information Security & Compliance
Biographical and Immigration Information
Ms. Yumiko Tanaka is a citizen and national of Japan. At the time this engagement was initiated, Ms. Tanaka held H-1B nonimmigrant status, with a validity period extending through November 18, 2025. Ms. Tanaka joined Lumos Analytics Inc. in February 2021 and has served as Director, Information Security & Compliance since July 2022. In this role, she oversees Lumos's enterprise information security program, including SOC 2 Type II compliance, ISO 27001 certification maintenance, vulnerability management, and cloud security architecture across Lumos's Meridian Technologies and GCP environments.
EB-2 Qualification Basis
Ms. Tanaka qualifies for EB-2 classification as an Advanced Degree Professional. She holds a Master of Science (M.S.) in Cybersecurity from Carnegie Mellon University, conferred in 2017, and a Bachelor of Engineering (B.Eng.) in Information Engineering from the University of Tokyo, conferred in 2015. Her advanced degree in Cybersecurity, together with her progressive post-baccalaureate experience and professional certification (CISSP), provides a strong foundation for EB-2 classification.
SOC Code and Offered Salary
The position was classified under SOC Code 15-1212 (Information Security Analysts). The offered annual salary for the position is $260,000.
Prevailing Wage Determination
The PWD request was filed with the NPWC on June 26, 2023. The PWD was received on October 2, 2023, and established the prevailing wage at Level IV (fully competent) at $185,910 per year for the applicable metropolitan statistical area. The offered salary of $260,000 exceeds the prevailing wage by $74,090, representing a margin of approximately 39.9% above the prevailing wage.
Recruitment Campaign
The supervised recruitment campaign for the Tanaka position commenced on October 23, 2023, and concluded on December 4, 2023. The recruitment steps were conducted on the same schedule and using the same methods as described above for Mr. Aguilar-Reyes. Sunday newspaper advertisements were placed in The Peninsula Gazette on October 29 and November 5, 2023; a SWA job order was placed via CalJOBS; a ten-day internal posting was displayed at the Lumos worksite; an online advertisement was placed in FinTech Talent Weekly; a campus posting was made through the Baxter University Career Center; and the position was circulated through Lumos's employee referral program.
Recruitment Results
A total of nine (9) resumes were received. After a thorough and good-faith review, zero (0) qualified U.S. workers were identified. The dispositions were as follows:
•  Five (5) applicants lacked the minimum educational requirement of a Master's degree in Cybersecurity, Information Systems, or a closely related field;
•  Two (2) applicants lacked the required Certified Information Systems Security Professional (CISSP) certification; and
•  Two (2) applicants lacked the required experience in SOC 2 Type II and ISO 27001 compliance implementation.
A detailed recruitment report was prepared and is maintained in the PERM audit file.
PERM Application
The PERM application for Ms. Tanaka was filed on January 8, 2024, and was assigned Case Number A-24401-00219. The priority date is January 8, 2024. The application was certified on March 1, 2024, without audit.
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 experience in information security, including two (2) years of experience in SOC 2 Type II and ISO 27001 compliance implementation;
•  Certified Information Systems Security Professional (CISSP) certification; and
•  Experience securing cloud-native SaaS platforms (Meridian Technologies/GCP).
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 beneficiary.
•  Total flat fees for four (4) beneficiaries: $50,000 ($12,500 × 4).
•  USCIS I-140 filing fee per case: $700 (as set forth in the USCIS fee schedule effective at the time of filing).
•  Total USCIS I-140 filing fees: $2,800 ($700 × 4).
•  USCIS Premium Processing fee per case (Form I-907): $2,500.
•  Total USCIS Premium Processing fees: $10,000 ($2,500 × 4).
•  DOL PERM filing fee: $0 per case. The Department of Labor does not charge a filing fee for the submission of the ETA Form 9089 PERM labor certification application.
•  Recruitment advertising costs: Passed through to the client at actual cost, without markup, as incurred in connection with the mandatory PERM recruitment campaigns. Total actual recruitment advertising costs across all four cases: $12,340.
Total Engagement Cost: $75,140
The total engagement cost of $75,140 represents the sum of flat legal fees ($50,000), USCIS filing fees ($2,800), USCIS premium processing fees ($10,000), and pass-through recruitment advertising costs ($12,340). This total was $460 under the initial estimate provided to the client at the outset of the engagement, primarily because actual recruitment advertising costs ($12,340) came in below the estimated amount ($12,800).
B. Invoice Summary Table
All five invoices have been paid in full. There is no outstanding balance on Matter No. 1008-00004. The final payment (Invoice No. 5) was received on March 25, 2024.
C. Advertising Cost Breakdown
The following is a breakdown of the recruitment advertising costs passed through to the client:
•  Newspaper advertisements (*The Peninsula Gazette*): Two Sunday insertions were required per position under 20 CFR § 656.17(e)(1)(i)(A). The cost was approximately $1,800 per pair of Sunday advertisements. For four positions, the total newspaper advertising cost was approximately $7,200.
•  Professional journal online advertisements (*FinTech Talent Weekly*, published by Creston Media Group, Inc.): One online advertisement per position was placed as a required additional recruitment step. The cost was approximately $950 per posting. For four positions, the total professional journal advertising cost was approximately $3,800.
•  State Workforce Agency posting via CalJOBS: $0 per posting. The CalJOBS system does not charge employers for job order postings.
•  Internal posting / company website posting: $0 per posting. No external cost was incurred for the mandatory ten-day internal posting at the Lumos worksite.
•  Baxter University Career Center posting: Nominal cost of $0–$250 per posting, depending on the position and posting duration.
•  Employee referral program posting: $0 per posting. No external cost was incurred for the internal employee referral program recruitment step.
•  Total actual recruitment advertising costs: $12,340 (compared to the $12,800 estimate provided at engagement).
The difference between estimated and actual advertising costs ($460) was attributable to minor volume discounts obtained by Broadgate Compliance Services LLC from The Peninsula Gazette for the placement of multiple advertisements on the same insertion dates.
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) with USCIS for beneficiaries physically present in the United States, or consular processing through the National Visa Center and a U.S. embassy or consulate abroad for beneficiaries who prefer or are required to obtain their immigrant visas outside the United States.
The availability of the I-485 filing option depends on whether the beneficiary's priority date is "current" under the applicable preference category and chargeability area as published in the monthly Department of State Visa Bulletin. The analysis below addresses the current visa bulletin status and recommended next steps for each beneficiary.
A. Rajan Mehta (India — EB-2)
Priority Date: December 18, 2023
As an India-born EB-2 beneficiary, Mr. Mehta faces a significant visa bulletin backlog. The EB-2 India final action date has been substantially retrogressed for many years, reflecting the persistent oversubscription of employment-based immigrant visas by nationals of India. Based on current Department of State visa bulletin trends and historical movement patterns, Mr. Mehta's priority date of December 18, 2023, is unlikely to become current for several years — potentially a decade or longer under current conditions, absent legislative reform.
Mr. Mehta's H-1B nonimmigrant status remains valid through September 14, 2025. Upon the expiration of his current H-1B validity period, Lumos should plan for H-1B extensions in one-year increments beyond the standard six-year maximum period of H-1B stay. Such extensions are available under Section 106(a) of the American Competitiveness in the Twenty-First Century Act ("AC21"), codified at 8 U.S.C. § 1184(g)(4), which permits H-1B extensions for aliens who are the beneficiaries of approved I-140 petitions but whose priority dates are not yet current. These one-year extensions may be renewed indefinitely until the priority date becomes current and Mr. Mehta is able to file for adjustment of status.
Recommendation: Calderwood & Harkness LLP should advise Lumos regarding the following strategic options for Mr. Mehta:
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 Researcher) categories. The EB-1 category is not subject to the same level of retrogression as EB-2 India, and a successful EB-1 petition could substantially accelerate Mr. Mehta's path to permanent residence.
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") category in the Department of State visa bulletin for purposes of the EB-2 preference category. The EB-2 rest-of-world final action date is generally current or near-current, meaning that there is typically no significant backlog for EB-2 beneficiaries chargeable to countries other than India, China, Mexico, and the Philippines (the countries subject to separate per-country limits that are frequently oversubscribed).
Based on the current visa bulletin, Dr. Varga's priority date of December 18, 2023, is likely current, making her immediately eligible for the filing of a Form I-485 application to adjust status to that of a lawful permanent resident. Dr. Varga's H-1B status remains valid through March 2, 2026, providing ample time for the I-485 adjudication process, which typically takes twelve to eighteen months at present processing times.
Recommendation: Calderwood & Harkness LLP should propose a new engagement to Lumos for the preparation and filing of Dr. Varga's I-485 adjustment of status application, together with concurrent applications for an Employment Authorization Document (Form I-765, EAD) and Advance Parole travel authorization (Form I-131). The concurrent filing of the I-765 and I-131 will provide Dr. Varga with independent work authorization and the ability to travel internationally during the pendency of the I-485, without reliance on the maintenance of her H-1B status.
C. Tomás Aguilar-Reyes (Mexico — EB-2)
Priority Date: January 8, 2024
Mexico has historically experienced some periods of retrogression in the EB-2 category, though the severity of the backlog has varied over time and has generally been less pronounced than the India EB-2 backlog. Based on the current visa bulletin, the EB-2 final action dates for Mexico indicate that priority dates in the range of Mr. Aguilar-Reyes's January 8, 2024, date may be current or nearly current, depending on the specific bulletin month. The firm should verify current visa bulletin availability prior to any filing.
Critical Timing Consideration: Mr. Aguilar-Reyes's L-1A nonimmigrant status is set to expire on July 30, 2024. This expiration date creates an urgent need for status planning. The following options should be evaluated and discussed with the client and beneficiary promptly:
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, regardless of the expiration of his underlying L-1A status. Concurrent I-765 EAD and I-131 Advance Parole applications should be included with the I-485 filing.
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 priority date is not yet current.
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 is the most time-sensitive issue arising from the closure of this matter. A new engagement proposal should be transmitted no later than mid-May 2024, with the objective of filing the appropriate applications well in advance of the July 30, 2024, L-1A expiration date.
D. Yumiko Tanaka (Japan — EB-2)
Priority Date: January 8, 2024
Japan is classified under the "All Chargeability Areas Except Those Listed" (rest of world) category in the visa bulletin for purposes of the EB-2 preference category. As noted above in connection with Dr. Varga, the EB-2 rest-of-world final action date is generally current. Ms. Tanaka's priority date of January 8, 2024, is therefore likely current, making her eligible for I-485 adjustment of status filing.
Ms. Tanaka's H-1B status remains valid through November 18, 2025. There is no immediate status expiration concern, and ample time remains for the preparation and filing of an I-485 application and for USCIS adjudication.
Recommendation: Calderwood & Harkness LLP should propose a new engagement to Lumos for the preparation and filing of Ms. Tanaka's I-485 adjustment of status application, together with concurrent I-765 EAD and I-131 Advance Parole applications.
E. General Recommendation
Based on the analysis set forth above, Calderwood & Harkness LLP should promptly send a formal letter to Marcus Whitfield (General Counsel) and Janelle Kwon (HR Manager — Immigration Contact) at Lumos Analytics Inc. advising on the next steps outlined in Sections VI.A through VI.D above and proposing a new engagement for the following services:
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 beneficiary prefers consular processing — that is, obtaining an immigrant visa through an interview at a U.S. embassy or consulate abroad rather than adjusting status within the United States — that option should be discussed with the beneficiary and the client and documented in the engagement for the next phase of the process. Consular processing may be preferable for beneficiaries who anticipate extended international travel or who have personal reasons for preferring to process abroad.
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 supervised recruitment was completed, whichever is later. This retention obligation applies regardless of whether the PERM application is certified, denied, or withdrawn, and exists to ensure that the employer can produce the required audit file in the event of a DOL audit or investigation.
Based on the filing dates in this matter, the minimum retention periods for PERM audit files are as follows:
•  Mehta and Varga: PERM applications filed December 18, 2023. Five-year retention period extends through at least December 18, 2028.
•  Aguilar-Reyes and Tanaka: PERM applications filed January 8, 2024. Five-year retention period extends through at least January 8, 2029.
The PERM audit file for each beneficiary includes, at a minimum, the following documentation:
•  Prevailing wage determination issued by the NPWC;
•  Complete recruitment documentation, including:
•  SWA job order confirmation and posting evidence (CalJOBS);
•  Newspaper tear sheets or proofs of publication for both Sunday advertisements in The Peninsula Gazette;
•  Online professional journal advertisement records (FinTech Talent Weekly);
•  Internal posting confirmation (ten-day posting at Lumos worksite);
•  Campus posting confirmation (Baxter University Career Center);
•  Employee referral program posting documentation;
•  Recruitment report prepared by the firm documenting the results of the recruitment campaign, including the number of applicants, the qualifications of each applicant, and the lawful job-related reason for rejecting each U.S. worker applicant;
•  Signed copies of the ETA Form 9089 as filed with the DOL;
•  All resumes received in response to the recruitment campaign;
•  All correspondence with applicants, including interview scheduling communications; and
•  Any additional documentation generated during the recruitment process.
Lumos Analytics Inc. has been advised of its obligation to maintain these audit files and has confirmed its understanding of the retention requirements.
B. Calderwood & Harkness LLP File Retention
In accordance with the firm's document retention policy, closed immigration matter files are retained for a minimum period of seven (7) years from the date of matter closure. For this matter, the seven-year retention period extends through at least April 30, 2031.
Upon formal closure of this matter, all physical and electronic files will be transferred to the firm's off-site storage facility and integrated into the firm's electronic document management system under Matter No. 1008-00004. The key contents of the retained file include:
•  Executed engagement letter dated June 12, 2023;
•  All correspondence with the client (Marcus Whitfield and Janelle Kwon at Lumos Analytics Inc.), including email communications, letters, and memoranda;
•  All correspondence with government agencies (DOL, USCIS, NPWC);
•  Copies of all filed PERM applications (ETA Form 9089) for all four beneficiaries;
•  Copies of all filed I-140 petitions (Form I-140) for all four beneficiaries;
•  USCIS I-140 approval notices for all four beneficiaries;
•  DOL PERM certification notices for all four beneficiaries;
•  Prevailing wage determinations for all four positions;
•  Recruitment materials, including advertisements, posting confirmations, and proof-of-publication records;
•  Recruitment compliance checklists prepared by Tiffany Rosenthal;
•  Recruitment reports for all four PERM applications;
•  All applicant resumes and correspondence;
•  Billing records, including all five invoices and payment confirmations;
•  Internal memoranda, including this matter closing memorandum; and
•  Any other documents generated or received in connection with this engagement.
C. Client File Transmission
Upon the closing of this matter, copies of the following documents were transmitted to Janelle Kwon at Lumos Analytics Inc. for the company's permanent records:
•  I-140 approval notices (Form I-797, Notice of Action) for all four beneficiaries;
•  PERM labor certification (ETA Form 9089) certified copies for all four beneficiaries;
•  Copies of the filed PERM applications and I-140 petitions, including all supporting documentation;
•  Prevailing wage determination letters for all four positions; and
•  A summary of PERM audit file retention requirements and recommended file organization protocols.
Lumos has been advised of its independent obligation to maintain the complete PERM audit files at its principal place of business (2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303), or at another location that is accessible and can be made available to the DOL within a reasonable time in the event of an audit. The firm has recommended that Lumos designate a specific custodian for immigration compliance files and establish a calendaring system to track retention deadlines.
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 notification of matter closure has been transmitted to Marcus Whitfield (General Counsel) and Janelle Kwon (HR Manager — Immigration Contact) at Lumos Analytics Inc. via email on April 30, 2024. The client notification confirmed the successful completion of all four cases, summarized the final outcomes, and indicated that the firm would be contacting Lumos separately to discuss next steps regarding adjustment of status and consular processing for the beneficiaries, as outlined in Section VI of this memorandum.
Matter Number 1008-00004 is hereby marked closed_completed in the firm's matter management system, effective April 30, 2024. No further time entries, disbursements, or billing activity should be recorded against this matter number. Any future work for Lumos Analytics Inc. in connection with the next phase of the green card process for these beneficiaries, or for any other immigration matter, should be opened under a new matter number upon execution of a new engagement letter.
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 protected by the attorney-client privilege and the attorney work product doctrine. It is intended solely for internal use by the attorneys and staff of Calderwood & Harkness LLP identified herein and should not be disclosed to any third party without the prior written consent of the responsible partner. Distribution to the client has been made separately and is limited to the matter closure notification referenced in Section IX.
Beneficiary | Position | SOC Code | Citizenship | PERM Case No. | Priority Date | PERM Certified | I-140 Receipt No. | I-140 Filed | I-140 Approved | EB-2 Basis
Rajan Mehta | VP, Engineering — Core Platform | 15-1252 | India | A-23401-83756 | 12/18/2023 | 02/14/2024 | SRC-24-901-12340 | 02/22/2024 | 03/07/2024 | Advanced Degree (M.S.)
Lina Varga | Sr. Dir., Data Science & ML | 15-2051 | Hungary | A-23401-83761 | 12/18/2023 | 02/14/2024 | SRC-24-901-12345 | 02/22/2024 | 03/08/2024 | Advanced Degree (Ph.D.)
Tomás Aguilar-Reyes | VP, Product — Fintech Solutions | 11-2021 | Mexico | A-24401-00214 | 01/08/2024 | 03/01/2024 | SRC-24-901-15560 | 03/08/2024 | 03/22/2024 | Advanced Degree (MBA)
Yumiko Tanaka | Dir., InfoSec & Compliance | 15-1212 | Japan | A-24401-00219 | 01/08/2024 | 03/01/2024 | SRC-24-901-15565 | 03/08/2024 | 03/21/2024 | Advanced Degree (M.S.)
Invoice No. | Date | Amount | Description | Status
1 | June 15, 2023 | $25,000.00 | 50% retainer on flat fees (4 beneficiaries × $12,500 × 50%) | PAID
2 | October 30, 2023 | $6,890.00 | Recruitment advertising costs — Mehta & Varga campaigns | PAID
3 | November 15, 2023 | $5,450.00 | Recruitment advertising costs — Aguilar-Reyes & Tanaka campaigns | PAID
4 | February 26, 2024 | $31,400.00 | Remaining 50% flat fee ($25,000) + Mehta I-140 filing & premium processing ($3,200) + Varga I-140 filing & premium processing ($3,200) | PAID
5 | March 11, 2024 | $6,400.00 | Aguilar-Reyes I-140 filing & premium processing ($3,200) + Tanaka I-140 filing & premium processing ($3,200) | PAID
$75,140.00 | Total Billed and Collected | All Paid
Date | Milestone
June 12, 2023 | Engagement letter signed by Marcus Whitfield on behalf of Lumos Analytics Inc.; Matter No. 1008-00004 opened
June 15, 2023 | Invoice No. 1 issued — 50% retainer on flat fees ($25,000)
June 26, 2023 | Prevailing wage determination requests filed with the National Prevailing Wage Center (NPWC) for all four positions
September 8, 2023 | Prevailing wage determination received for Mehta (SOC 15-1252, Level IV, $198,744/year)
September 11, 2023 | Prevailing wage determination received for Varga (SOC 15-2051, Level IV, $191,360/year)
October 2, 2023 | Prevailing wage determinations received for Aguilar-Reyes (SOC 11-2021, Level III, $176,842/year) and Tanaka (SOC 15-1212, Level IV, $185,910/year)
October 9, 2023 | Recruitment campaign commenced for Mehta and Varga positions
October 15, 2023 | First Sunday newspaper advertisement published in The Peninsula Gazette (Mehta and Varga)
October 22, 2023 | Second Sunday newspaper advertisement published in The Peninsula Gazette (Mehta and Varga)
October 23, 2023 | Recruitment campaign commenced for Aguilar-Reyes and Tanaka positions
October 29, 2023 | First Sunday newspaper advertisement published in The Peninsula Gazette (Aguilar-Reyes and Tanaka)
October 30, 2023 | Invoice No. 2 issued — Recruitment advertising costs for Mehta & Varga campaigns ($6,890)
November 5, 2023 | Second Sunday newspaper advertisement published in The Peninsula Gazette (Aguilar-Reyes and Tanaka)
November 15, 2023 | Invoice No. 3 issued — Recruitment advertising costs for Aguilar-Reyes & Tanaka campaigns ($5,450)
November 20, 2023 | Recruitment campaign concluded for Mehta and Varga positions
December 4, 2023 | Recruitment campaign concluded for Aguilar-Reyes and Tanaka positions
December 18, 2023 | PERM applications (ETA Form 9089) filed for Mehta (Case No. A-23401-83756) and Varga (Case No. A-23401-83761) — Priority Date: December 18, 2023
January 8, 2024 | PERM applications (ETA Form 9089) filed for Aguilar-Reyes (Case No. A-24401-00214) and Tanaka (Case No. A-24401-00219) — Priority Date: January 8, 2024
February 14, 2024 | PERM certifications received for Mehta and Varga
February 22, 2024 | I-140 petitions filed with Premium Processing for Mehta (Receipt No. SRC-24-901-12340) and Varga (Receipt No. SRC-24-901-12345)
February 26, 2024 | Invoice No. 4 issued — Remaining 50% flat fee + Mehta & Varga I-140 filing and premium processing fees ($31,400)
March 1, 2024 | PERM certifications received for Aguilar-Reyes and Tanaka
March 7, 2024 | I-140 approved for Mehta
March 8, 2024 | I-140 approved for Varga; I-140 petitions filed with Premium Processing for Aguilar-Reyes (Receipt No. SRC-24-901-15560) and Tanaka (Receipt No. SRC-24-901-15565)
March 11, 2024 | Invoice No. 5 issued — Aguilar-Reyes & Tanaka I-140 filing and premium processing fees ($6,400)
March 21, 2024 | I-140 approved for Tanaka
March 22, 2024 | I-140 approved for Aguilar-Reyes
March 25, 2024 | Final payment received (Invoice No. 5) — all invoices paid in full
April 30, 2024 | Matter closed; closing memorandum prepared and distributed