Significant Public Benefit Parole for Entrepreneurs

June 28, 2018 The Honorable Kirstjen Nielsen Secretary Department of Homeland Security 3801 Nebraska Avenue, NW Washington, DC 20528 Dear Secretary Nielsen, On behalf of the Consumer Technology Association (CTA) and our more than 2,200 member companies 80 percent of whom are small businesses and startups I would like to express strong opposition to DHS Docket No USCIS-2015-0006, the proposed rescission of the International Entrepreneur Rule (IER). Many of CTAs member companies were founded by immigrants. These companies create American jobs, contribute significantly to our economy and help ensure the United States remains a leader in the global tech sector. I urge you to reconsider the proposed elimination of the IER. Immigrant entrepreneurs create American jobs. A 2016 study from the National Foundation for American Policy shows immigrants founded just over half of Americas billion-dollar startups. Today, 1.7 million Americans work at top tech companies founded by immigrants or the children of immigrants, and these companies added an average of 760 jobs apiece to our economy. Our industry shares the administrations commitment to job creation and economic growth, but rescinding the IER runs counter to that commitment. Scrapping this rule will leave American jobs on the table. According to your departments 2017 estimate, 2,940 entrepreneurs would be eligible to start businesses in the United States each year under the IER. If those companies are not founded in the U.S., they will take their job creation elsewhere. Our competitors are vying to attract the best job creators. This year the United Kingdom launched a new expedited visa for startup founders and entrepreneurs; France has a fast-track French Tech Visa specifically for startup founders; and Canada has a dedicated program for startup founders to build their companies there and achieve permanent residence. If we want to maintain our economic leadership, the U.S. needs a modern immigration system, including a means for international entrepreneurs to build American businesses. Preserving the IER is essential to competing with other nations for the worlds best talent. In your proposed revision of the IER, the Department of Homeland Security says the EB-5 and E-2 programs already enable certain entrepreneurs to start businesses in the United States. While technically true in a narrow sense, those two programs alone are not sufficient to attract all the job-creating entrepreneurs our economy needs. Absent a dedicated startup visa, we need pathways such as the IER in place. The IER is specifically tailored to maximize economic impact and deter abuse. By demonstrating they have received significant investment of capital from qualified U.S. investors and their startups have substantial potential for rapid growth and job creation, IER recipients indisputably will offer public benefit to the U.S. We believe your department has the authority to implement and administer the International Entrepreneur Rule as written. Opting to instead rescind the IER would be an economic loss to our country. Thank you for your consideration. We look forward to working with you to strengthen our economy and our immigration system. Sincerely, Gary Shapiro President and CEO