1008-00004 · Client 1008 · I-140 Filing

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LUMOS ANALYTICS INC.

[Company Logo]

2240 Embarcadero Way, Suite 600 Palo Alto, CA 94303

Telephone: (650) 555-0140

Email: legal@lumosanalytics.com

EIN: 84-3291057

[DATE]

Template drafted by Derek Okonkwo, Calderwood & Harkness LLP, for execution by authorized Lumos officers. Bracketed fields must be completed prior to execution and filing.

U.S. Citizenship and Immigration Services Texas Service Center 6046 N Belt Line Road Irving, TX 75038

Re: Form I-140, Immigrant Petition for Alien Worker

Petitioner: Lumos Analytics Inc. Beneficiary: [FULL NAME OF BENEFICIARY] Classification: Employment-Based Second Preference (EB-2) — Advanced Degree Professional PERM Labor Certification Case No.: [CASE NUMBER] Priority Date: [PRIORITY DATE]

Dear Sir or Madam:

I. Introduction and Purpose of This Letter

This letter is submitted on behalf of Lumos Analytics Inc. ("Lumos" or "Petitioner") in support of the Form I-140, Immigrant Petition for Alien Worker, filed for [BENEFICIARY NAME] (the "Beneficiary"). Lumos is petitioning under the Employment-Based Second Preference (EB-2) classification for an Advanced Degree Professional, pursuant to Section 203(b)(2) of the Immigration and Nationality Act ("INA"), 8 U.S.C. § 1153(b)(2), and the implementing regulations at 8 C.F.R. § 204.5(k).

The approved PERM labor certification, U.S. Department of Labor ETA Form 9089, Case No. [CASE NUMBER], with a priority date of [PRIORITY DATE], is enclosed with this petition as a supporting exhibit. The labor certification was obtained in full compliance with the applicable provisions of 20 C.F.R. Part 656 and confirms that no qualified, willing, and available U.S. workers were identified for the offered position during the supervised recruitment process.

The purpose of this letter is to provide the adjudicating officer with a comprehensive overview of the Petitioner, the offered position, and the Beneficiary's qualifications, and to confirm the following:

1. The bona fide nature of the permanent, full-time job offer extended to the Beneficiary;

2. Lumos's ongoing ability to pay the offered wage from the priority date through the present and into the future, as required under 8 C.F.R. § 204.5(g)(2);

3. The Beneficiary's possession of the requisite advanced degree and professional qualifications that meet or exceed the minimum requirements of the offered position as set forth in the approved PERM labor certification; and

4. The eligibility of the position and the Beneficiary for classification under the EB-2 (Advanced Degree Professional) preference category.

Lumos respectfully submits that the petition satisfies all statutory and regulatory requirements for approval and requests that U.S. Citizenship and Immigration Services ("USCIS") adjudicate this petition favorably.

II. Description of the Petitioning Employer

Lumos Analytics Inc. is a C-Corporation incorporated under the laws of the State of Delaware. The company's registered agent in Delaware is Keystone Registered Agents LLC, located at 850 New Burton Road, Suite 201, Dover, DE 19904. Lumos is qualified to transact business in the State of California and maintains its principal place of business and corporate headquarters at 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303. The company's federal Employer Identification Number (EIN) is 84-3291057.

Lumos operates in the enterprise software-as-a-service (SaaS) and financial technology (fintech) sectors. The company's core product is an artificial intelligence-driven credit risk analytics and automated underwriting platform that serves mid-market and enterprise financial institutions, including banks, credit unions, and alternative lenders. Lumos's proprietary platform leverages advanced machine learning algorithms, large-scale data processing pipelines, and real-time decisioning engines to enable its clients to assess borrower creditworthiness with greater speed, accuracy, and regulatory compliance than traditional underwriting methods permit.

Since its founding in 2019, Lumos has experienced rapid and sustained growth. The company currently employs approximately 312 full-time employees as of June 2023, spanning engineering, data science, product management, sales, marketing, customer success, legal, compliance, and administrative functions. For the fiscal year ending December 31, 2023, Lumos recorded annual revenue of approximately $87.4 million, reflecting strong year-over-year growth consistent with the company's trajectory since inception.

Lumos's growth and financial stability are further supported by significant institutional investment. The company's Series B financing round was led by Ridgeline Equity Partners, LP, a prominent private equity and growth equity firm, which currently holds a 38.2% equity stake in Lumos. The capital raised through the Series B round and subsequent financing activities has enabled Lumos to invest heavily in research and development, expand its engineering and data science teams, and accelerate product development to meet growing market demand for AI-driven credit risk solutions.

The company's senior leadership team includes the following key officers:

• Chief Executive Officer: Priya Chandrasekaran

• General Counsel: Marcus Whitfield

• Vice President, People Operations: Sonia Elliston

Lumos is a well-established, operationally mature, and financially sound enterprise employer with the organizational capacity, resources, and commitment necessary to sponsor the Beneficiary for permanent residence and to employ the Beneficiary on a full-time, permanent basis in the offered position.

III. Bona Fide Job Offer

Lumos Analytics Inc. hereby confirms that it has made, and continues to extend, a bona fide, permanent, full-time job offer to the Beneficiary for the position of [POSITION TITLE].

[Template instruction: Insert the applicable position title from the following list based on the Beneficiary being sponsored:]

• Rajan Mehta — Vice President, Engineering — Core Platform

• Lina Varga — Senior Director, Data Science & Machine Learning

• Tomás Aguilar-Reyes — Vice President, Product — Fintech Solutions

• Yumiko Tanaka — Director, Information Security & Compliance

The offered position is located at Lumos's principal place of business and corporate headquarters at 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303. The Beneficiary will report to work at this location and perform the duties of the position at this worksite, consistent with the terms set forth in the approved PERM labor certification.

The offered annual salary for this position is [OFFERED SALARY], payable in accordance with Lumos's standard bi-weekly payroll cycle. This offered wage equals or exceeds the prevailing wage determination of [PWD AMOUNT] issued by the U.S. Department of Labor's National Prevailing Wage Center for this position, job zone, and geographic area of intended employment.

[Template instruction: Insert the applicable salary and prevailing wage data from the following list:]

• Rajan Mehta: Offered salary of $285,000 per year; prevailing wage of $198,744 per year, Wage Level IV, SOC Code 15-1252 (Software Developers)

• Lina Varga: Offered salary of $310,000 per year; prevailing wage of $191,360 per year, Wage Level IV, SOC Code 15-2051 (Data Scientists)

• Tomás Aguilar-Reyes: Offered salary of $275,000 per year; prevailing wage of $176,842 per year, Wage Level III, SOC Code 11-2021 (Marketing Managers)

• Yumiko Tanaka: Offered salary of $260,000 per year; prevailing wage of $185,910 per year, Wage Level IV, SOC Code 15-1212 (Information Security Analysts)

The offered salary is a full-time annual salary, and the Beneficiary is also entitled to participate in Lumos's standard employee benefits program, which includes, among other benefits, employer-sponsored health insurance (medical, dental, and vision), a 401(k) retirement savings plan with employer matching contributions, paid time off, equity incentive compensation, and professional development allowances.

Lumos wishes to emphasize that this job offer is not contingent upon or conditioned in any way upon the approval of this Form I-140 petition. The Beneficiary is currently employed by Lumos in the offered position and has been performing the duties of the role on a full-time basis. The Beneficiary will continue to be employed in this role following the approval of this petition and the ultimate adjustment of the Beneficiary's immigration status to that of a lawful permanent resident of the United States.

The job offer was made in good faith and reflects Lumos's genuine and continuing need for a qualified professional in this position to support the company's business operations, product development, and strategic growth objectives.

IV. Position Description and Minimum Requirements

The position of [POSITION TITLE] carries the following minimum requirements, as set forth in the approved PERM labor certification (ETA Form 9089). These requirements represent the actual minimum qualifications that Lumos requires for the position and reflect the employer's genuine business needs. The requirements were not tailored to the Beneficiary's qualifications but rather were established based on the operational demands of the role and the specialized expertise necessary to perform the position's essential functions.

[Template instruction: Insert the applicable position description block from the subsections below based on the Beneficiary being sponsored. Delete the inapplicable subsections prior to execution.]

A. Vice President, Engineering — Core Platform (Rajan Mehta)

Standard Occupational Classification (SOC) Code: 15-1252 (Software Developers)

Minimum Educational Requirement: Master's degree in Computer Science or a closely related field.

Minimum Experience Requirement: Five (5) years of progressive post-baccalaureate experience in software engineering, including a minimum of two (2) years of specialized experience in distributed systems architecture.

Special Requirements: The position requires demonstrated experience with Apache Kafka, Kubernetes, and microservices-based architectures operating at enterprise scale, including platforms processing 100 million or more daily transactions. The Vice President, Engineering — Core Platform is responsible for leading the design, development, and operational management of Lumos's core platform infrastructure, overseeing a team of software engineers and architects, setting technical strategy for the company's real-time data processing and decisioning systems, and ensuring the reliability, scalability, and security of mission-critical production environments that serve Lumos's financial institution clients.

B. Senior Director, Data Science & Machine Learning (Lina Varga)

Standard Occupational Classification (SOC) Code: 15-2051 (Data Scientists)

Minimum Educational Requirement: Ph.D. (doctoral degree) in Statistics, Computer Science, or a closely related quantitative field.

Minimum Experience Requirement: Three (3) years of post-doctoral experience in applied machine learning, including a minimum of two (2) years of specialized experience in financial services credit modeling.

Special Requirements: The position requires a publication record in peer-reviewed academic journals on topics related to statistical learning methods, including but not limited to ensemble methods, Bayesian inference, or deep learning architectures applied to structured data. The position additionally requires demonstrated proficiency in Python, R, and TensorFlow. The Senior Director, Data Science & Machine Learning is responsible for leading Lumos's data science and machine learning organization, developing and deploying proprietary credit risk models, directing research into novel statistical methods for underwriting automation, and ensuring model fairness, interpretability, and regulatory compliance in accordance with applicable federal and state fair lending requirements.

C. Vice President, Product — Fintech Solutions (Tomás Aguilar-Reyes)

Standard Occupational Classification (SOC) Code: 11-2021 (Marketing Managers)

Minimum Educational Requirement: Master's degree in Business Administration, Finance, or a closely related field.

Minimum Experience Requirement: Five (5) years of progressive experience in fintech product management, including a minimum of three (3) years of experience managing cross-functional teams of fifteen (15) or more members.

Special Requirements: The position requires demonstrated experience with regulatory frameworks applicable to the financial services and consumer lending industries, specifically including the Dodd-Frank Wall Street Reform and Consumer Protection Act and Consumer Financial Protection Bureau ("CFPB") guidelines, as applied to automated lending products and credit decisioning platforms. The Vice President, Product — Fintech Solutions is responsible for defining the product vision and roadmap for Lumos's fintech product suite, translating client and market requirements into product specifications, coordinating engineering, design, data science, compliance, and go-to-market teams, and ensuring that Lumos's products satisfy evolving regulatory requirements while delivering superior client value.

D. Director, Information Security & Compliance (Yumiko Tanaka)

Standard Occupational Classification (SOC) Code: 15-1212 (Information Security Analysts)

Minimum Educational Requirement: Master's degree in Cybersecurity, Information Systems, or a closely related field.

Minimum Experience Requirement: Four (4) years of progressive experience in information security, including a minimum of two (2) years of specialized experience in SOC 2 Type II and ISO 27001 compliance implementation.

Special Requirements: The position requires current Certified Information Systems Security Professional (CISSP) certification, as well as demonstrated experience securing cloud-native SaaS platforms deployed on Ridgeway Industries (Meridian Technologies) and/or Aldermere Technologies (GCP). The Director, Information Security & Compliance is responsible for leading Lumos's enterprise information security program, developing and maintaining security policies and procedures, managing vulnerability assessment and penetration testing programs, overseeing compliance certifications and audits (including SOC 2 Type II and ISO 27001), ensuring compliance with applicable data protection and privacy regulations, and safeguarding the confidentiality, integrity, and availability of client data entrusted to Lumos's platform.

The above minimum requirements accurately reflect the actual minimum qualifications that Lumos requires for the offered position and were established based on the genuine operational and business needs of the company. The requirements are commensurate with the seniority, complexity, and strategic importance of the role within Lumos's organizational structure and are consistent with industry standards for comparable positions at similarly situated enterprise SaaS and fintech companies.

V. EB-2 Classification — Advanced Degree Professional

Lumos respectfully submits that the offered position qualifies for classification under the Employment-Based Second Preference (EB-2) category as an Advanced Degree Professional, pursuant to INA § 203(b)(2)(A), 8 U.S.C. § 1153(b)(2)(A), and 8 C.F.R. § 204.5(k)(2).

Under the governing statute and regulations, the EB-2 classification is available to members of the professions holding advanced degrees, or the equivalent thereof, whose services are sought by a United States employer. An "advanced degree" is defined by regulation as any United States academic or professional degree, or a foreign equivalent degree, above the baccalaureate level. 8 C.F.R. § 204.5(k)(2). A United States baccalaureate degree or a foreign equivalent degree followed by at least five years of progressive experience in the specialty is considered the equivalent of a master's degree. Id.

The offered position requires, at minimum, a Master's degree (or, in the case of the Senior Director, Data Science & Machine Learning position, a doctoral degree) or its foreign equivalent in a specified field of study, as detailed in Section IV above. This educational requirement satisfies the threshold for an advanced degree position under the EB-2 classification.

The Beneficiary holds the following qualifying advanced degree or degrees:

[Template instruction: Insert the applicable educational credential from the following list:]

• Rajan Mehta: Master of Science (M.S.) in Computer Science, Indian Institute of Technology Bombay (IIT Bombay), conferred in 2014.

• Lina Varga: Doctor of Philosophy (Ph.D.) in Statistics, ETH Glenrock Assurance (Swiss Federal Institute of Technology Glenrock Assurance), conferred in 2016.

• Tomás Aguilar-Reyes: Master of Business Administration (MBA), IPADE Business School, conferred in 2013, supplemented by more than five (5) years of progressive experience in fintech product management.

• Yumiko Tanaka: Master of Science (M.S.) in Cybersecurity, Carnegie Mellon University, conferred in 2017.

Each Beneficiary's advanced degree meets or exceeds the minimum educational requirements for the respective position as stated in the approved PERM labor certification. The Beneficiary's academic credentials have been verified through the credential evaluation and supporting documentation enclosed with this petition. Accordingly, the Beneficiary qualifies as an Advanced Degree Professional within the meaning of the statute and regulations, and the position is properly classified under the EB-2 preference category.

VI. Beneficiary's Qualifications

Lumos confirms that the Beneficiary meets or exceeds all of the minimum requirements for the offered position as set forth in the approved PERM labor certification (ETA Form 9089). The Beneficiary possesses the requisite educational credentials, professional experience, specialized skills, and any additional certifications required by the position. A summary of the Beneficiary's qualifications is set forth below, and detailed supporting documentation — including copies of academic diplomas, transcripts, credential evaluations, the Beneficiary's curriculum vitae, and evidence of the Beneficiary's current immigration status — is enclosed with this petition.

[Template instruction: Insert the applicable beneficiary qualifications block from the subsections below. Delete the inapplicable subsections prior to execution.]

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

Education:

• Master of Science (M.S.) in Computer Science, Indian Institute of Technology Bombay (IIT Bombay), 2014

• Bachelor of Technology (B.Tech.) in Computer Science, National Institute of Technology Tiruchirappalli (NIT Trichy), 2012

Current Title at Lumos Analytics Inc.: Vice President, Engineering — Core Platform

Current Immigration Status: H-1B nonimmigrant status, valid through September 14, 2025

Summary of Qualifications: Mr. Mehta holds a Master's degree in Computer Science from one of India's premier technical institutions and has accumulated extensive post-baccalaureate experience in software engineering and distributed systems architecture. His professional experience significantly exceeds the minimum requirement of five years of progressive post-baccalaureate experience, including the two-year minimum in distributed systems architecture. Mr. Mehta has direct, hands-on experience with Apache Kafka, Kubernetes, and microservices architectures at enterprise scale, including the design and management of platforms processing well in excess of 100 million daily transactions. His qualifications meet and exceed all minimum requirements and special requirements for this position as set forth in the approved PERM labor certification.

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

Education:

• Doctor of Philosophy (Ph.D.) in Statistics, ETH Glenrock Assurance (Swiss Federal Institute of Technology Glenrock Assurance), 2016

• Master of Science (M.Sc.) in Applied Mathematics, Eötvös Loránd University (ELTE), Budapest, Hungary, 2012

Current Title at Lumos Analytics Inc.: Senior Director, Data Science & Machine Learning

Current Immigration Status: H-1B nonimmigrant status, valid through March 2, 2026

Summary of Qualifications: Dr. Varga holds a doctoral degree in Statistics from ETH Glenrock Assurance, one of Europe's foremost research universities, and a Master's degree in Applied Mathematics from Eötvös Loránd University. Her post-doctoral professional experience in applied machine learning, including significant tenure in financial services credit modeling, substantially exceeds the minimum three-year post-doctoral experience requirement. Dr. Varga has authored and co-authored multiple publications in peer-reviewed academic journals on topics related to statistical learning methods, satisfying the publication record requirement. She is proficient in Python, R, and TensorFlow, as required by the position. Her qualifications meet and exceed all minimum requirements and special requirements for this position as set forth in the approved PERM labor certification.

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

Education:

• Master of Business Administration (MBA), IPADE Business School, Mexico City, Mexico, 2013

• Bachelor of Science (B.S.) in Industrial Engineering, Tecnológico de Monterrey (ITESM), Monterrey, Mexico, 2010

Current Title at Lumos Analytics Inc.: Vice President, Product — Fintech Solutions

Current Immigration Status: L-1A intracompany transferee nonimmigrant status, valid through July 30, 2024

Summary of Qualifications: Mr. Aguilar-Reyes holds a Master of Business Administration degree from IPADE Business School, one of Latin America's leading graduate business programs, and a Bachelor of Science degree in Industrial Engineering from Tecnológico de Monterrey. His progressive experience in fintech product management significantly exceeds the minimum five-year experience requirement, and his track record of managing cross-functional teams of fifteen or more members exceeds the three-year minimum for that specific requirement. Mr. Aguilar-Reyes has demonstrated expertise in the regulatory frameworks applicable to automated lending products, including the Dodd-Frank Act and CFPB guidelines, as required by the position. His qualifications meet and exceed all minimum requirements and special requirements for this position as set forth in the approved PERM labor certification.

D. Yumiko Tanaka — Director, Information Security & Compliance

Education:

• Master of Science (M.S.) in Cybersecurity, Carnegie Mellon University, Pittsburgh, Pennsylvania, 2017

• Bachelor of Engineering (B.Eng.) in Information Engineering, University of Tokyo, Tokyo, Japan, 2015

Current Title at Lumos Analytics Inc.: Director, Information Security & Compliance

Current Immigration Status: H-1B nonimmigrant status, valid through November 18, 2025

Summary of Qualifications: Ms. Tanaka holds a Master of Science degree in Cybersecurity from Carnegie Mellon University, widely recognized as a leading institution in the field of information security, and a Bachelor of Engineering degree in Information Engineering from the University of Tokyo. Her progressive experience in information security, including specialized experience in SOC 2 Type II and ISO 27001 compliance implementation, exceeds the minimum four-year experience requirement. Ms. Tanaka holds a current Certified Information Systems Security Professional (CISSP) certification, as required by the position, and has extensive experience securing cloud-native SaaS platforms deployed on both Ridgeway Industries (Meridian Technologies) and Aldermere Technologies (GCP). Her qualifications meet and exceed all minimum requirements and special requirements for this position as set forth in the approved PERM labor certification.

Detailed supporting documentation verifying the Beneficiary's educational credentials, professional experience, certifications, and current immigration status is enclosed with this petition as referenced in the enclosure list appended to this letter.

VII. Ability to Pay the Offered Wage

Lumos Analytics Inc. confirms its ability to pay the offered wage of [OFFERED SALARY] per year to the Beneficiary from the priority date of [PRIORITY DATE] onward, and continuing through the present, as required under 8 C.F.R. § 204.5(g)(2).

The governing regulation provides that a petition for an employment-based immigrant visa shall include evidence that the prospective United States employer has the ability to pay the offered wage. The petitioner may demonstrate its ability to pay through one or more of the following: (1) annual reports, federal tax returns, or audited financial statements demonstrating the employer's net income or net current assets; (2) evidence that the beneficiary is already employed by the petitioner and the petitioner has been paying the beneficiary's wages; or (3) any other evidence that the employer has the financial capacity to pay the offered wage.

Lumos submits the following evidence in support of its ability to pay:

1. Annual Revenue: Lumos's total annual revenue for the fiscal year ending December 31, 2023, was approximately $87.4 million. The offered salary of [OFFERED SALARY] represents a small fraction — less than one-half of one percent — of the company's total annual revenue.

2. Number of Employees: As of June 2023, Lumos employed approximately 312 full-time employees across all functions and departments. The company has maintained a robust and growing workforce throughout the relevant period, and the offered position is one of many professional roles within the organization.

3. Capitalization and Institutional Investment: Lumos is a well-capitalized enterprise SaaS company. The company's Series B financing round was led by Ridgeline Equity Partners, LP, a growth equity firm that currently holds a 38.2% equity stake in Lumos. The company's strong capitalization and institutional backing provide additional assurance of its financial stability and its ongoing capacity to meet its employment obligations, including the payment of the offered wage to the Beneficiary.

4. Current Payment of Wages: The Beneficiary is currently employed by Lumos in the offered position, and Lumos has consistently paid the Beneficiary's current salary in full and on time. The Beneficiary's current compensation is at or above the offered wage set forth in the PERM labor certification and the prevailing wage determination.

In further support of Lumos's ability to pay the offered wage, the following financial documentation is enclosed with this petition:

• Relevant portions of Lumos Analytics Inc.'s federal corporate income tax returns (IRS Form 1120) for the applicable tax years

• Audited financial statements for the most recently completed fiscal year, as applicable

• Such additional financial documentation as may be necessary to demonstrate the petitioner's financial capacity to pay the offered wage

Based on the foregoing, Lumos has amply demonstrated its ability to pay the offered wage from the priority date through the present and has the financial capacity to continue to pay the offered wage at or above the prevailing wage for the duration of the Beneficiary's employment.

VIII. PERM Labor Certification

Lumos Analytics Inc. obtained an approved PERM labor certification from the U.S. Department of Labor, Employment and Training Administration, Office of Foreign Labor Certification, for the offered position. The approved ETA Form 9089 is enclosed with this petition as a supporting exhibit.

The relevant PERM labor certification details are as follows:

Case Number: [CASE NUMBER]

[Template instruction: Insert the applicable PERM case number from the following list:]

• Rajan Mehta: A-23401-83756

• Lina Varga: A-23401-83761

• Tomás Aguilar-Reyes: A-24401-00214

• Yumiko Tanaka: A-24401-00219

Priority Date: [PRIORITY DATE]

[Template instruction: Insert the applicable priority date from the following list:]

• Rajan Mehta: December 18, 2023

• Lina Varga: December 18, 2023

• Tomás Aguilar-Reyes: January 8, 2024

• Yumiko Tanaka: January 8, 2024

The PERM labor certification was obtained through a full supervised recruitment process conducted in strict compliance with the requirements of 20 C.F.R. § 656.17. The recruitment process included all mandatory and additional recruitment steps prescribed by the regulations, and Lumos attests that the recruitment results demonstrated that no qualified, willing, and available U.S. workers were identified for the offered position at the prevailing wage during the recruitment period. The approved labor certification confirms that the employment of the Beneficiary in the offered position will not adversely affect the wages and working conditions of similarly employed U.S. workers.

IX. Conclusion and Request for Approval

Based on the foregoing, Lumos Analytics Inc. respectfully requests that U.S. Citizenship and Immigration Services approve the enclosed Form I-140, Immigrant Petition for Alien Worker, on behalf of [BENEFICIARY NAME].

In support of this request, Lumos has demonstrated the following:

1. The position of [POSITION TITLE] represents a bona fide job offer for a permanent, full-time role at a salary of [OFFERED SALARY] per year, which equals or exceeds the applicable prevailing wage determination;

2. The Beneficiary possesses an advanced degree and professional qualifications that meet or exceed all of the minimum requirements for the offered position as set forth in the approved PERM labor certification;

3. The petition is properly classified under the Employment-Based Second Preference (EB-2) category for an Advanced Degree Professional, pursuant to INA § 203(b)(2)(A) and 8 C.F.R. § 204.5(k)(2);

4. Lumos has demonstrated its ability to pay the offered wage from the priority date through the present and into the future, as required under 8 C.F.R. § 204.5(g)(2); and

5. An approved PERM labor certification, obtained through a full supervised recruitment process in compliance with 20 C.F.R. Part 656, is enclosed with the petition.

Should USCIS require any additional information, documentation, or clarification in connection with the adjudication of this petition, please do not hesitate to contact the undersigned officers of Lumos Analytics Inc. or the company's immigration counsel at the following address:

Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104

Attention: Derek Okonkwo, Lead Associate

Telephone: (415) 555-0278

Email: dokonkwo@calderwoodharkness.com

Matter Number: 1008-00004

We thank USCIS for its time and consideration of this petition and look forward to a favorable adjudication.

Respectfully submitted,

LUMOS ANALYTICS INC.

By: ________

Name: Priya Chandrasekaran

Title: Chief Executive Officer

Date: ________

LUMOS ANALYTICS INC.

By: ________

Name: Sonia Elliston

Title: Vice President, People Operations

Date: ________

Enclosures

The following documents are enclosed with this petition. This enclosure list should be customized to reflect the specific Beneficiary and supporting materials submitted:

1. Form I-140, Immigrant Petition for Alien Worker, with filing fee of $700.00

2. Form I-907, Request for Premium Processing Service, with premium processing fee of $2,500.00

3. Approved PERM Labor Certification (ETA Form 9089), Case No. [CASE NUMBER]

4. Prevailing Wage Determination issued by the National Prevailing Wage Center

5. Beneficiary's educational credentials, including:

(a) Copies of academic diplomas and degree certificates

(b) Official academic transcripts

6. Beneficiary's curriculum vitae / professional resume

7. Evidence of Beneficiary's current nonimmigrant status (copy of Form I-797 Approval Notice for H-1B or L-1A classification, as applicable)

8. Evidence of Petitioner's ability to pay the offered wage, including:

(a) Relevant portions of federal corporate income tax returns (IRS Form 1120) for the applicable tax year(s)

(b) Audited financial statements, if applicable

9. Any additional supporting documentation as applicable to the specific Beneficiary

TEMPLATE USE INSTRUCTIONS

This is a blank form template prepared by Calderwood & Harkness LLP for use by Lumos Analytics Inc. in connection with I-140 immigrant petition filings for the following beneficiaries: Rajan Mehta, Lina Varga, Tomás Aguilar-Reyes, and Yumiko Tanaka. All bracketed fields indicated by [ ] throughout this letter must be completed with the applicable beneficiary-specific information prior to execution and filing. Sections containing multiple beneficiary-specific subsections (Sections IV, V, VI, and VIII) should be edited to retain only the subsection applicable to the specific beneficiary for whom the letter is being executed; all inapplicable subsections should be deleted. This template should be printed on official Lumos Analytics Inc. letterhead and must be executed by both signatories (CEO and VP, People Operations) prior to submission to USCIS. Questions regarding the use of this template should be directed to Derek Okonkwo, Calderwood & Harkness LLP, at (415) 555-0278 or dokonkwo@calderwoodharkness.com.

LUMOS ANALYTICS INC.
[Company Logo]
2240 Embarcadero Way, Suite 600 Palo Alto, CA 94303
Telephone: (650) 555-0140
Email: legal@lumosanalytics.com
EIN: 84-3291057
[DATE]
Template drafted by Derek Okonkwo, Calderwood & Harkness LLP, for execution by authorized Lumos officers. Bracketed fields must be completed prior to execution and filing.
U.S. Citizenship and Immigration Services Texas Service Center 6046 N Belt Line Road Irving, TX 75038
Re: Form I-140, Immigrant Petition for Alien Worker
Petitioner: Lumos Analytics Inc. Beneficiary: [FULL NAME OF BENEFICIARY] Classification: Employment-Based Second Preference (EB-2) — Advanced Degree Professional PERM Labor Certification Case No.: [CASE NUMBER] Priority Date: [PRIORITY DATE]
Dear Sir or Madam:
I. Introduction and Purpose of This Letter
This letter is submitted on behalf of Lumos Analytics Inc. ("Lumos" or "Petitioner") in support of the Form I-140, Immigrant Petition for Alien Worker, filed for [BENEFICIARY NAME] (the "Beneficiary"). Lumos is petitioning under the Employment-Based Second Preference (EB-2) classification for an Advanced Degree Professional, pursuant to Section 203(b)(2) of the Immigration and Nationality Act ("INA"), 8 U.S.C. § 1153(b)(2), and the implementing regulations at 8 C.F.R. § 204.5(k).
The approved PERM labor certification, U.S. Department of Labor ETA Form 9089, Case No. [CASE NUMBER], with a priority date of [PRIORITY DATE], is enclosed with this petition as a supporting exhibit. The labor certification was obtained in full compliance with the applicable provisions of 20 C.F.R. Part 656 and confirms that no qualified, willing, and available U.S. workers were identified for the offered position during the supervised recruitment process.
The purpose of this letter is to provide the adjudicating officer with a comprehensive overview of the Petitioner, the offered position, and the Beneficiary's qualifications, and to confirm the following:
1.  The bona fide nature of the permanent, full-time job offer extended to the Beneficiary;
2.  Lumos's ongoing ability to pay the offered wage from the priority date through the present and into the future, as required under 8 C.F.R. § 204.5(g)(2);
3.  The Beneficiary's possession of the requisite advanced degree and professional qualifications that meet or exceed the minimum requirements of the offered position as set forth in the approved PERM labor certification; and
4.  The eligibility of the position and the Beneficiary for classification under the EB-2 (Advanced Degree Professional) preference category.
Lumos respectfully submits that the petition satisfies all statutory and regulatory requirements for approval and requests that U.S. Citizenship and Immigration Services ("USCIS") adjudicate this petition favorably.
II. Description of the Petitioning Employer
Lumos Analytics Inc. is a C-Corporation incorporated under the laws of the State of Delaware. The company's registered agent in Delaware is Keystone Registered Agents LLC, located at 850 New Burton Road, Suite 201, Dover, DE 19904. Lumos is qualified to transact business in the State of California and maintains its principal place of business and corporate headquarters at 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303. The company's federal Employer Identification Number (EIN) is 84-3291057.
Lumos operates in the enterprise software-as-a-service (SaaS) and financial technology (fintech) sectors. The company's core product is an artificial intelligence-driven credit risk analytics and automated underwriting platform that serves mid-market and enterprise financial institutions, including banks, credit unions, and alternative lenders. Lumos's proprietary platform leverages advanced machine learning algorithms, large-scale data processing pipelines, and real-time decisioning engines to enable its clients to assess borrower creditworthiness with greater speed, accuracy, and regulatory compliance than traditional underwriting methods permit.
Since its founding in 2019, Lumos has experienced rapid and sustained growth. The company currently employs approximately 312 full-time employees as of June 2023, spanning engineering, data science, product management, sales, marketing, customer success, legal, compliance, and administrative functions. For the fiscal year ending December 31, 2023, Lumos recorded annual revenue of approximately $87.4 million, reflecting strong year-over-year growth consistent with the company's trajectory since inception.
Lumos's growth and financial stability are further supported by significant institutional investment. The company's Series B financing round was led by Ridgeline Equity Partners, LP, a prominent private equity and growth equity firm, which currently holds a 38.2% equity stake in Lumos. The capital raised through the Series B round and subsequent financing activities has enabled Lumos to invest heavily in research and development, expand its engineering and data science teams, and accelerate product development to meet growing market demand for AI-driven credit risk solutions.
The company's senior leadership team includes the following key officers:
•  Chief Executive Officer: Priya Chandrasekaran
•  General Counsel: Marcus Whitfield
•  Vice President, People Operations: Sonia Elliston
Lumos is a well-established, operationally mature, and financially sound enterprise employer with the organizational capacity, resources, and commitment necessary to sponsor the Beneficiary for permanent residence and to employ the Beneficiary on a full-time, permanent basis in the offered position.
III. Bona Fide Job Offer
Lumos Analytics Inc. hereby confirms that it has made, and continues to extend, a bona fide, permanent, full-time job offer to the Beneficiary for the position of [POSITION TITLE].
[Template instruction: Insert the applicable position title from the following list based on the Beneficiary being sponsored:]
•  Rajan Mehta — Vice President, Engineering — Core Platform
•  Lina Varga — Senior Director, Data Science & Machine Learning
•  Tomás Aguilar-Reyes — Vice President, Product — Fintech Solutions
•  Yumiko Tanaka — Director, Information Security & Compliance
The offered position is located at Lumos's principal place of business and corporate headquarters at 2240 Embarcadero Way, Suite 600, Palo Alto, CA 94303. The Beneficiary will report to work at this location and perform the duties of the position at this worksite, consistent with the terms set forth in the approved PERM labor certification.
The offered annual salary for this position is [OFFERED SALARY], payable in accordance with Lumos's standard bi-weekly payroll cycle. This offered wage equals or exceeds the prevailing wage determination of [PWD AMOUNT] issued by the U.S. Department of Labor's National Prevailing Wage Center for this position, job zone, and geographic area of intended employment.
[Template instruction: Insert the applicable salary and prevailing wage data from the following list:]
•  Rajan Mehta: Offered salary of $285,000 per year; prevailing wage of $198,744 per year, Wage Level IV, SOC Code 15-1252 (Software Developers)
•  Lina Varga: Offered salary of $310,000 per year; prevailing wage of $191,360 per year, Wage Level IV, SOC Code 15-2051 (Data Scientists)
•  Tomás Aguilar-Reyes: Offered salary of $275,000 per year; prevailing wage of $176,842 per year, Wage Level III, SOC Code 11-2021 (Marketing Managers)
•  Yumiko Tanaka: Offered salary of $260,000 per year; prevailing wage of $185,910 per year, Wage Level IV, SOC Code 15-1212 (Information Security Analysts)
The offered salary is a full-time annual salary, and the Beneficiary is also entitled to participate in Lumos's standard employee benefits program, which includes, among other benefits, employer-sponsored health insurance (medical, dental, and vision), a 401(k) retirement savings plan with employer matching contributions, paid time off, equity incentive compensation, and professional development allowances.
Lumos wishes to emphasize that this job offer is not contingent upon or conditioned in any way upon the approval of this Form I-140 petition. The Beneficiary is currently employed by Lumos in the offered position and has been performing the duties of the role on a full-time basis. The Beneficiary will continue to be employed in this role following the approval of this petition and the ultimate adjustment of the Beneficiary's immigration status to that of a lawful permanent resident of the United States.
The job offer was made in good faith and reflects Lumos's genuine and continuing need for a qualified professional in this position to support the company's business operations, product development, and strategic growth objectives.
IV. Position Description and Minimum Requirements
The position of [POSITION TITLE] carries the following minimum requirements, as set forth in the approved PERM labor certification (ETA Form 9089). These requirements represent the actual minimum qualifications that Lumos requires for the position and reflect the employer's genuine business needs. The requirements were not tailored to the Beneficiary's qualifications but rather were established based on the operational demands of the role and the specialized expertise necessary to perform the position's essential functions.
[Template instruction: Insert the applicable position description block from the subsections below based on the Beneficiary being sponsored. Delete the inapplicable subsections prior to execution.]
A. Vice President, Engineering — Core Platform (Rajan Mehta)
Standard Occupational Classification (SOC) Code: 15-1252 (Software Developers)
Minimum Educational Requirement: Master's degree in Computer Science or a closely related field.
Minimum Experience Requirement: Five (5) years of progressive post-baccalaureate experience in software engineering, including a minimum of two (2) years of specialized experience in distributed systems architecture.
Special Requirements: The position requires demonstrated experience with Apache Kafka, Kubernetes, and microservices-based architectures operating at enterprise scale, including platforms processing 100 million or more daily transactions. The Vice President, Engineering — Core Platform is responsible for leading the design, development, and operational management of Lumos's core platform infrastructure, overseeing a team of software engineers and architects, setting technical strategy for the company's real-time data processing and decisioning systems, and ensuring the reliability, scalability, and security of mission-critical production environments that serve Lumos's financial institution clients.
B. Senior Director, Data Science & Machine Learning (Lina Varga)
Standard Occupational Classification (SOC) Code: 15-2051 (Data Scientists)
Minimum Educational Requirement: Ph.D. (doctoral degree) in Statistics, Computer Science, or a closely related quantitative field.
Minimum Experience Requirement: Three (3) years of post-doctoral experience in applied machine learning, including a minimum of two (2) years of specialized experience in financial services credit modeling.
Special Requirements: The position requires a publication record in peer-reviewed academic journals on topics related to statistical learning methods, including but not limited to ensemble methods, Bayesian inference, or deep learning architectures applied to structured data. The position additionally requires demonstrated proficiency in Python, R, and TensorFlow. The Senior Director, Data Science & Machine Learning is responsible for leading Lumos's data science and machine learning organization, developing and deploying proprietary credit risk models, directing research into novel statistical methods for underwriting automation, and ensuring model fairness, interpretability, and regulatory compliance in accordance with applicable federal and state fair lending requirements.
C. Vice President, Product — Fintech Solutions (Tomás Aguilar-Reyes)
Standard Occupational Classification (SOC) Code: 11-2021 (Marketing Managers)
Minimum Educational Requirement: Master's degree in Business Administration, Finance, or a closely related field.
Minimum Experience Requirement: Five (5) years of progressive experience in fintech product management, including a minimum of three (3) years of experience managing cross-functional teams of fifteen (15) or more members.
Special Requirements: The position requires demonstrated experience with regulatory frameworks applicable to the financial services and consumer lending industries, specifically including the Dodd-Frank Wall Street Reform and Consumer Protection Act and Consumer Financial Protection Bureau ("CFPB") guidelines, as applied to automated lending products and credit decisioning platforms. The Vice President, Product — Fintech Solutions is responsible for defining the product vision and roadmap for Lumos's fintech product suite, translating client and market requirements into product specifications, coordinating engineering, design, data science, compliance, and go-to-market teams, and ensuring that Lumos's products satisfy evolving regulatory requirements while delivering superior client value.
D. Director, Information Security & Compliance (Yumiko Tanaka)
Standard Occupational Classification (SOC) Code: 15-1212 (Information Security Analysts)
Minimum Educational Requirement: Master's degree in Cybersecurity, Information Systems, or a closely related field.
Minimum Experience Requirement: Four (4) years of progressive experience in information security, including a minimum of two (2) years of specialized experience in SOC 2 Type II and ISO 27001 compliance implementation.
Special Requirements: The position requires current Certified Information Systems Security Professional (CISSP) certification, as well as demonstrated experience securing cloud-native SaaS platforms deployed on Ridgeway Industries (Meridian Technologies) and/or Aldermere Technologies (GCP). The Director, Information Security & Compliance is responsible for leading Lumos's enterprise information security program, developing and maintaining security policies and procedures, managing vulnerability assessment and penetration testing programs, overseeing compliance certifications and audits (including SOC 2 Type II and ISO 27001), ensuring compliance with applicable data protection and privacy regulations, and safeguarding the confidentiality, integrity, and availability of client data entrusted to Lumos's platform.
The above minimum requirements accurately reflect the actual minimum qualifications that Lumos requires for the offered position and were established based on the genuine operational and business needs of the company. The requirements are commensurate with the seniority, complexity, and strategic importance of the role within Lumos's organizational structure and are consistent with industry standards for comparable positions at similarly situated enterprise SaaS and fintech companies.
V. EB-2 Classification — Advanced Degree Professional
Lumos respectfully submits that the offered position qualifies for classification under the Employment-Based Second Preference (EB-2) category as an Advanced Degree Professional, pursuant to INA § 203(b)(2)(A), 8 U.S.C. § 1153(b)(2)(A), and 8 C.F.R. § 204.5(k)(2).
Under the governing statute and regulations, the EB-2 classification is available to members of the professions holding advanced degrees, or the equivalent thereof, whose services are sought by a United States employer. An "advanced degree" is defined by regulation as any United States academic or professional degree, or a foreign equivalent degree, above the baccalaureate level. 8 C.F.R. § 204.5(k)(2). A United States baccalaureate degree or a foreign equivalent degree followed by at least five years of progressive experience in the specialty is considered the equivalent of a master's degree. Id.
The offered position requires, at minimum, a Master's degree (or, in the case of the Senior Director, Data Science & Machine Learning position, a doctoral degree) or its foreign equivalent in a specified field of study, as detailed in Section IV above. This educational requirement satisfies the threshold for an advanced degree position under the EB-2 classification.
The Beneficiary holds the following qualifying advanced degree or degrees:
[Template instruction: Insert the applicable educational credential from the following list:]
•  Rajan Mehta: Master of Science (M.S.) in Computer Science, Indian Institute of Technology Bombay (IIT Bombay), conferred in 2014.
•  Lina Varga: Doctor of Philosophy (Ph.D.) in Statistics, ETH Glenrock Assurance (Swiss Federal Institute of Technology Glenrock Assurance), conferred in 2016.
•  Tomás Aguilar-Reyes: Master of Business Administration (MBA), IPADE Business School, conferred in 2013, supplemented by more than five (5) years of progressive experience in fintech product management.
•  Yumiko Tanaka: Master of Science (M.S.) in Cybersecurity, Carnegie Mellon University, conferred in 2017.
Each Beneficiary's advanced degree meets or exceeds the minimum educational requirements for the respective position as stated in the approved PERM labor certification. The Beneficiary's academic credentials have been verified through the credential evaluation and supporting documentation enclosed with this petition. Accordingly, the Beneficiary qualifies as an Advanced Degree Professional within the meaning of the statute and regulations, and the position is properly classified under the EB-2 preference category.
VI. Beneficiary's Qualifications
Lumos confirms that the Beneficiary meets or exceeds all of the minimum requirements for the offered position as set forth in the approved PERM labor certification (ETA Form 9089). The Beneficiary possesses the requisite educational credentials, professional experience, specialized skills, and any additional certifications required by the position. A summary of the Beneficiary's qualifications is set forth below, and detailed supporting documentation — including copies of academic diplomas, transcripts, credential evaluations, the Beneficiary's curriculum vitae, and evidence of the Beneficiary's current immigration status — is enclosed with this petition.
[Template instruction: Insert the applicable beneficiary qualifications block from the subsections below. Delete the inapplicable subsections prior to execution.]
A. Rajan Mehta — Vice President, Engineering — Core Platform
Education:
•  Master of Science (M.S.) in Computer Science, Indian Institute of Technology Bombay (IIT Bombay), 2014
•  Bachelor of Technology (B.Tech.) in Computer Science, National Institute of Technology Tiruchirappalli (NIT Trichy), 2012
Current Title at Lumos Analytics Inc.: Vice President, Engineering — Core Platform
Current Immigration Status: H-1B nonimmigrant status, valid through September 14, 2025
Summary of Qualifications: Mr. Mehta holds a Master's degree in Computer Science from one of India's premier technical institutions and has accumulated extensive post-baccalaureate experience in software engineering and distributed systems architecture. His professional experience significantly exceeds the minimum requirement of five years of progressive post-baccalaureate experience, including the two-year minimum in distributed systems architecture. Mr. Mehta has direct, hands-on experience with Apache Kafka, Kubernetes, and microservices architectures at enterprise scale, including the design and management of platforms processing well in excess of 100 million daily transactions. His qualifications meet and exceed all minimum requirements and special requirements for this position as set forth in the approved PERM labor certification.
B. Lina Varga — Senior Director, Data Science & Machine Learning
Education:
•  Doctor of Philosophy (Ph.D.) in Statistics, ETH Glenrock Assurance (Swiss Federal Institute of Technology Glenrock Assurance), 2016
•  Master of Science (M.Sc.) in Applied Mathematics, Eötvös Loránd University (ELTE), Budapest, Hungary, 2012
Current Title at Lumos Analytics Inc.: Senior Director, Data Science & Machine Learning
Current Immigration Status: H-1B nonimmigrant status, valid through March 2, 2026
Summary of Qualifications: Dr. Varga holds a doctoral degree in Statistics from ETH Glenrock Assurance, one of Europe's foremost research universities, and a Master's degree in Applied Mathematics from Eötvös Loránd University. Her post-doctoral professional experience in applied machine learning, including significant tenure in financial services credit modeling, substantially exceeds the minimum three-year post-doctoral experience requirement. Dr. Varga has authored and co-authored multiple publications in peer-reviewed academic journals on topics related to statistical learning methods, satisfying the publication record requirement. She is proficient in Python, R, and TensorFlow, as required by the position. Her qualifications meet and exceed all minimum requirements and special requirements for this position as set forth in the approved PERM labor certification.
C. Tomás Aguilar-Reyes — Vice President, Product — Fintech Solutions
Education:
•  Master of Business Administration (MBA), IPADE Business School, Mexico City, Mexico, 2013
•  Bachelor of Science (B.S.) in Industrial Engineering, Tecnológico de Monterrey (ITESM), Monterrey, Mexico, 2010
Current Title at Lumos Analytics Inc.: Vice President, Product — Fintech Solutions
Current Immigration Status: L-1A intracompany transferee nonimmigrant status, valid through July 30, 2024
Summary of Qualifications: Mr. Aguilar-Reyes holds a Master of Business Administration degree from IPADE Business School, one of Latin America's leading graduate business programs, and a Bachelor of Science degree in Industrial Engineering from Tecnológico de Monterrey. His progressive experience in fintech product management significantly exceeds the minimum five-year experience requirement, and his track record of managing cross-functional teams of fifteen or more members exceeds the three-year minimum for that specific requirement. Mr. Aguilar-Reyes has demonstrated expertise in the regulatory frameworks applicable to automated lending products, including the Dodd-Frank Act and CFPB guidelines, as required by the position. His qualifications meet and exceed all minimum requirements and special requirements for this position as set forth in the approved PERM labor certification.
D. Yumiko Tanaka — Director, Information Security & Compliance
Education:
•  Master of Science (M.S.) in Cybersecurity, Carnegie Mellon University, Pittsburgh, Pennsylvania, 2017
•  Bachelor of Engineering (B.Eng.) in Information Engineering, University of Tokyo, Tokyo, Japan, 2015
Current Title at Lumos Analytics Inc.: Director, Information Security & Compliance
Current Immigration Status: H-1B nonimmigrant status, valid through November 18, 2025
Summary of Qualifications: Ms. Tanaka holds a Master of Science degree in Cybersecurity from Carnegie Mellon University, widely recognized as a leading institution in the field of information security, and a Bachelor of Engineering degree in Information Engineering from the University of Tokyo. Her progressive experience in information security, including specialized experience in SOC 2 Type II and ISO 27001 compliance implementation, exceeds the minimum four-year experience requirement. Ms. Tanaka holds a current Certified Information Systems Security Professional (CISSP) certification, as required by the position, and has extensive experience securing cloud-native SaaS platforms deployed on both Ridgeway Industries (Meridian Technologies) and Aldermere Technologies (GCP). Her qualifications meet and exceed all minimum requirements and special requirements for this position as set forth in the approved PERM labor certification.
Detailed supporting documentation verifying the Beneficiary's educational credentials, professional experience, certifications, and current immigration status is enclosed with this petition as referenced in the enclosure list appended to this letter.
VII. Ability to Pay the Offered Wage
Lumos Analytics Inc. confirms its ability to pay the offered wage of [OFFERED SALARY] per year to the Beneficiary from the priority date of [PRIORITY DATE] onward, and continuing through the present, as required under 8 C.F.R. § 204.5(g)(2).
The governing regulation provides that a petition for an employment-based immigrant visa shall include evidence that the prospective United States employer has the ability to pay the offered wage. The petitioner may demonstrate its ability to pay through one or more of the following: (1) annual reports, federal tax returns, or audited financial statements demonstrating the employer's net income or net current assets; (2) evidence that the beneficiary is already employed by the petitioner and the petitioner has been paying the beneficiary's wages; or (3) any other evidence that the employer has the financial capacity to pay the offered wage.
Lumos submits the following evidence in support of its ability to pay:
1.  Annual Revenue: Lumos's total annual revenue for the fiscal year ending December 31, 2023, was approximately $87.4 million. The offered salary of [OFFERED SALARY] represents a small fraction — less than one-half of one percent — of the company's total annual revenue.
2.  Number of Employees: As of June 2023, Lumos employed approximately 312 full-time employees across all functions and departments. The company has maintained a robust and growing workforce throughout the relevant period, and the offered position is one of many professional roles within the organization.
3.  Capitalization and Institutional Investment: Lumos is a well-capitalized enterprise SaaS company. The company's Series B financing round was led by Ridgeline Equity Partners, LP, a growth equity firm that currently holds a 38.2% equity stake in Lumos. The company's strong capitalization and institutional backing provide additional assurance of its financial stability and its ongoing capacity to meet its employment obligations, including the payment of the offered wage to the Beneficiary.
4.  Current Payment of Wages: The Beneficiary is currently employed by Lumos in the offered position, and Lumos has consistently paid the Beneficiary's current salary in full and on time. The Beneficiary's current compensation is at or above the offered wage set forth in the PERM labor certification and the prevailing wage determination.
In further support of Lumos's ability to pay the offered wage, the following financial documentation is enclosed with this petition:
•  Relevant portions of Lumos Analytics Inc.'s federal corporate income tax returns (IRS Form 1120) for the applicable tax years
•  Audited financial statements for the most recently completed fiscal year, as applicable
•  Such additional financial documentation as may be necessary to demonstrate the petitioner's financial capacity to pay the offered wage
Based on the foregoing, Lumos has amply demonstrated its ability to pay the offered wage from the priority date through the present and has the financial capacity to continue to pay the offered wage at or above the prevailing wage for the duration of the Beneficiary's employment.
VIII. PERM Labor Certification
Lumos Analytics Inc. obtained an approved PERM labor certification from the U.S. Department of Labor, Employment and Training Administration, Office of Foreign Labor Certification, for the offered position. The approved ETA Form 9089 is enclosed with this petition as a supporting exhibit.
The relevant PERM labor certification details are as follows:
Case Number: [CASE NUMBER]
[Template instruction: Insert the applicable PERM case number from the following list:]
•  Rajan Mehta: A-23401-83756
•  Lina Varga: A-23401-83761
•  Tomás Aguilar-Reyes: A-24401-00214
•  Yumiko Tanaka: A-24401-00219
Priority Date: [PRIORITY DATE]
[Template instruction: Insert the applicable priority date from the following list:]
•  Rajan Mehta: December 18, 2023
•  Lina Varga: December 18, 2023
•  Tomás Aguilar-Reyes: January 8, 2024
•  Yumiko Tanaka: January 8, 2024
The PERM labor certification was obtained through a full supervised recruitment process conducted in strict compliance with the requirements of 20 C.F.R. § 656.17. The recruitment process included all mandatory and additional recruitment steps prescribed by the regulations, and Lumos attests that the recruitment results demonstrated that no qualified, willing, and available U.S. workers were identified for the offered position at the prevailing wage during the recruitment period. The approved labor certification confirms that the employment of the Beneficiary in the offered position will not adversely affect the wages and working conditions of similarly employed U.S. workers.
IX. Conclusion and Request for Approval
Based on the foregoing, Lumos Analytics Inc. respectfully requests that U.S. Citizenship and Immigration Services approve the enclosed Form I-140, Immigrant Petition for Alien Worker, on behalf of [BENEFICIARY NAME].
In support of this request, Lumos has demonstrated the following:
1.  The position of [POSITION TITLE] represents a bona fide job offer for a permanent, full-time role at a salary of [OFFERED SALARY] per year, which equals or exceeds the applicable prevailing wage determination;
2.  The Beneficiary possesses an advanced degree and professional qualifications that meet or exceed all of the minimum requirements for the offered position as set forth in the approved PERM labor certification;
3.  The petition is properly classified under the Employment-Based Second Preference (EB-2) category for an Advanced Degree Professional, pursuant to INA § 203(b)(2)(A) and 8 C.F.R. § 204.5(k)(2);
4.  Lumos has demonstrated its ability to pay the offered wage from the priority date through the present and into the future, as required under 8 C.F.R. § 204.5(g)(2); and
5.  An approved PERM labor certification, obtained through a full supervised recruitment process in compliance with 20 C.F.R. Part 656, is enclosed with the petition.
Should USCIS require any additional information, documentation, or clarification in connection with the adjudication of this petition, please do not hesitate to contact the undersigned officers of Lumos Analytics Inc. or the company's immigration counsel at the following address:
Calderwood & Harkness LLP 555 California Street, 32nd Floor San Francisco, CA 94104
Attention: Derek Okonkwo, Lead Associate
Telephone: (415) 555-0278
Email: dokonkwo@calderwoodharkness.com
Matter Number: 1008-00004
We thank USCIS for its time and consideration of this petition and look forward to a favorable adjudication.
Respectfully submitted,
LUMOS ANALYTICS INC.
By: ________
Name: Priya Chandrasekaran
Title: Chief Executive Officer
Date: ________
LUMOS ANALYTICS INC.
By: ________
Name: Sonia Elliston
Title: Vice President, People Operations
Date: ________
Enclosures
The following documents are enclosed with this petition. This enclosure list should be customized to reflect the specific Beneficiary and supporting materials submitted:
1.  Form I-140, Immigrant Petition for Alien Worker, with filing fee of $700.00
2.  Form I-907, Request for Premium Processing Service, with premium processing fee of $2,500.00
3.  Approved PERM Labor Certification (ETA Form 9089), Case No. [CASE NUMBER]
4.  Prevailing Wage Determination issued by the National Prevailing Wage Center
5.  Beneficiary's educational credentials, including:
(a) Copies of academic diplomas and degree certificates
(b) Official academic transcripts
(c) Credential evaluation report(s) from a NACES-member evaluation service, if applicable
6.  Beneficiary's curriculum vitae / professional resume
7.  Evidence of Beneficiary's current nonimmigrant status (copy of Form I-797 Approval Notice for H-1B or L-1A classification, as applicable)
8.  Evidence of Petitioner's ability to pay the offered wage, including:
(a) Relevant portions of federal corporate income tax returns (IRS Form 1120) for the applicable tax year(s)
(b) Audited financial statements, if applicable
(c) Such additional financial documentation as may be relevant
9.  Any additional supporting documentation as applicable to the specific Beneficiary
TEMPLATE USE INSTRUCTIONS
This is a blank form template prepared by Calderwood & Harkness LLP for use by Lumos Analytics Inc. in connection with I-140 immigrant petition filings for the following beneficiaries: Rajan Mehta, Lina Varga, Tomás Aguilar-Reyes, and Yumiko Tanaka. All bracketed fields indicated by [ ] throughout this letter must be completed with the applicable beneficiary-specific information prior to execution and filing. Sections containing multiple beneficiary-specific subsections (Sections IV, V, VI, and VIII) should be edited to retain only the subsection applicable to the specific beneficiary for whom the letter is being executed; all inapplicable subsections should be deleted. This template should be printed on official Lumos Analytics Inc. letterhead and must be executed by both signatories (CEO and VP, People Operations) prior to submission to USCIS. Questions regarding the use of this template should be directed to Derek Okonkwo, Calderwood & Harkness LLP, at (415) 555-0278 or dokonkwo@calderwoodharkness.com.

LUMOS ANALYTICS INC.

EIN: 84-3291057

LUMOS ANALYTICS INC.

LUMOS ANALYTICS INC.

TEMPLATE USE INSTRUCTIONS

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