yes thank you your honor robert how on behalf of g b international and mr park don't park the issue in this case is involves an individual in the company applying for permanent residence at us or a multinational executive in order to qualify the person the beneficiary mr park was required to have performed one year before he came to the united states in an executive capacity for the company that that years april two thousand and thirteen to april two thousand and fourteen there's not really any question at all that mr park was employed by the company by g b international not any question that he was employed as an executive by the company the issue in this case is whether mr parker was employed primarily in an executive capacity during that one year period april two thousand and thirteen to april two thousand and fourteen we submit that there are two things wrong with the decision made by the immigration service first of all they failed to consider important evidence so it's in the record in particular a declaration submitted by mr c e o pat a manager of the company describing what the company's business was the activities of the company sample invoices which showed which employees which subordinate employees were monitoring  contract i am the expert witness opinions submitted by two expert witnesses for a nd we submit also that the agency has made a legal error in it understanding of what it means to work in a court executive passed city so the question is didn't mr parks work in an executive capacity during this one year period oh the  question i guess is we need to understand what what the business of a company was or is and what the day to day activities are involved in taking care of the business of that company g b international is an export  exports goods manufactured in the united states primarily to south korea as well a few other countries primarily south korea but it involves purchasing equipment that's used in heavy position those are mentioned you know there are those those also appear for example in organizational charts and in the declaration submitted in a cover letter submitted by the company but it does not discuss the particular activities the day to day that it is that those negotiations as long as they're less than one hundred thousand dollars the that he talks about preparing the repo to further down preparing the reports that are necessary that mr park the executive is reviewing above the this is the nd paragraph there one area that mr tim was responsible for is marketing is doing the marketing work for the a company in this area are you i responsible for was marketing the marketing work that the company needs to do in this area he would follow up with potential customers that mr parker identified of the executive of the beneficiary and with the administrative assistance of miss him which sends the materials regarding g b i and so on he analyzes the price proposals for the negotiations with vendors and so on and so forth in addition  talks about the work that mrs kim damon kim had performed and she's the woman that was hired she was not present during the whole school year but hired i believe in august of two thousand and thirteen who in the company is performing the day to day activities the description of mr parks activities well he has a very detailed in his own declaration he provides a very detailed description of what he does and that's also discussed parks involvement in running the company and managing the company so that's why this declaration of mr package on sale pack is one that's not mentioned anywhere and not analyzed anywhere in the decision that i think a critical piece of evidence that the agency simply doesn't engage with it doesn't mention anywhere doesn't consider the evidence that's contained there that declaration is also supported the sample invoices that were submitted by the company that was in but about fifty pages of invoices sample invoices over a period of about five or six months showing what was going on in the company those invoices show that show that they list the sales contacts for various export import transactions that are going on those sales contacts in other words the people who  are the the producer of the equipment or the purchase of equipment these are they're going to deal with the sales contacts they're not going to deal with mr park executives but in terms of the day to day activities going on in the company those you know the sales contacts are the subordinate officials the rd very important piece of evidence that overlooked the expert declaration submitted by the two experts agency did refer to the expert declaration directly cited by us c i s in their very extensive letter however it is however the impulse from the from the letter and the arguments from the from the latter during the year before or during the year prior to arrival in the united states  up different from these definitions if anything i would i would expect that there that the that what they described in the occupational example is far more detail and far more restrictive than if they had simply gone too far to a four dollars whatever it is j i think yeah there i would i would it's ultimately a conclusion of the agency to provide lesser weight given that the agency has a more more concern on the definition of the but ultimately even is even if the even if the definitions from the experts were to be considered ultimately if they please and or even if analyst alice during the during the relevant period focuses on a complex organizational hierarchy the expert witnesses did not talk about that the agency says inherent to the definition the organization must have a subordinate level of managerial employees we  incorrect understanding those are that's not part of the r n a definition and we think that explains why the agency you know did felt it didn't have to engage with this very significant evidence mr paxton aeration and the expert witness 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