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July 16, 2026

RE:  Form I-129, H-1B Specialty Occupation Worker Petition
      Beneficiary:  Priya Sharma
      Petitioner:  Cortex Labs, Inc.
      Position:  Senior Machine Learning Engineer
      LCA Case No.:  I-XXX-XXXXX-XXXXXX

To Whom It May Concern:

Cortex Labs, Inc. (“Cortex Labs” or the “Petitioner”), a Delaware corporation with its principal place of business at 100 Innovation Way, San Francisco, California, respectfully submits this Form I-129, H-1B specialty occupation worker petition on behalf of Ms. Priya Sharma (“Beneficiary”) to authorize her temporary employment in the United States as a Senior Machine Learning Engineer. Petitioner requests H-1B classification for the period beginning October 1, 2026 through September 30, 2029, in conformity with the Department of Labor's certified Labor Condition Application (LCA) referenced above and with the controlling provisions of 8 CFR 214.2(h) and INA § 101(a)(15)(H)(i)(b).

I.  Background of Petitioner

Cortex Labs is a Series C applied machine-learning company headquartered in San Francisco, California. The company develops production-scale inference and evaluation infrastructure for foundation-model deployments across regulated industries — including healthcare diagnostics, financial risk modeling, and federal procurement screening. Cortex Labs currently employs 142 full-time personnel, of whom 96 are technical contributors across research, infrastructure, and applied engineering. The company's flagship platform, Cortex Inspect, is deployed in production environments at three of the ten largest U.S. health systems under business associate agreements that require SOC 2 Type II and HIPAA-compliance attestation.

Cortex Labs has raised $187 million in venture financing from leading institutional investors, has been issued seven U.S. patents in machine-learning evaluation methodology (six additional applications are pending), and publishes original applied research through its Cortex Labs Research division, including peer-reviewed papers at NeurIPS, ICML, and the ACL Anthology. The company carries an authorized stockholder base of 38 institutional and individual shareholders, maintains audited financial statements for fiscal years 2023 and 2024, and is current on all federal and state tax obligations. Cortex Labs is, and has been continuously since incorporation in 2019, a U.S. employer in good standing with the Internal Revenue Service and the State of California.

Petitioner has filed and maintained valid H-1B petitions on behalf of other specialty occupation workers since 2021, with all prior beneficiaries either continuing employment at the company in good standing or having progressed to other U.S. immigration classifications consistent with their long-term career plans. Petitioner is fully familiar with the regulatory framework, documentary standards, and compliance obligations attendant to the H-1B classification and approaches this filing with the utmost attention to evidentiary completeness.

II.  Description of the Proffered Position

The proffered position is a Senior Machine Learning Engineer reporting directly to the Director of Applied Research. The position is a full-time, salaried role with an annualized compensation of $182,000, which exceeds the prevailing wage level II for the SOC 15-1221 occupation code in the San Francisco, CA Metropolitan Statistical Area, as certified on the attached Labor Condition Application (LCA Case No. I-XXX-XXXXX-XXXXXX). The work location is Petitioner's San Francisco, California headquarters, and the position is not a telework, hybrid-from-outside-MSA, or third-party-placement arrangement.

The Senior Machine Learning Engineer is responsible for designing, implementing, and maintaining large-scale production inference pipelines for foundation-model evaluation, including (a) developing new benchmarking methodologies for hallucination detection and citation faithfulness in retrieval-augmented generation systems; (b) collaborating with the applied research team to translate academic findings from peer-reviewed publications into production-grade evaluation suites; (c) authoring internal technical specifications that govern evaluation reproducibility across Cortex Inspect's customer deployments; (d) leading quarterly architecture reviews of the inference stack and proposing data-driven refinements; and (e) mentoring Associate ML Engineers on advanced topics in distributed inference, calibration, and evaluation methodology. The position requires an existing mastery of transformer-based architectures, retrieval-augmented generation methodology, and the practical engineering judgment to translate statistical robustness criteria into shipping decisions.

The position is bound to the specialty occupation standard: it requires, at minimum, a bachelor's degree (or foreign equivalent) in computer science, machine learning, applied mathematics, electrical engineering, or a closely related quantitative field, plus progressive post-baccalaureate experience. Petitioner has prepared and attached the LCA referenced above, attesting that the offered wage ($182,000) exceeds the level II prevailing wage for SOC 15-1221 in the San Francisco MSA ($174,200 per the OES wage survey at the time of LCA certification), and that all working conditions attestations have been signed and posted in accordance with 20 CFR 655.734.

III.  Qualifications of the Beneficiary

The Beneficiary, Ms. Priya Sharma, possesses the requisite bachelor's degree and progressive specialty experience required for the proffered position. Ms. Sharma earned a Bachelor of Technology in Computer Science and Engineering from the Indian Institute of Technology Madras, graduating with distinction in 2017, and a Master of Science in Computer Science (concentration: Machine Learning) from Carnegie Mellon University in 2019. Both degrees are in fields directly related to the specialty occupation duties enumerated above.

Since 2019, Ms. Sharma has accumulated six (6) years of progressive specialty experience. From 2019 through 2022 she served as a Machine Learning Engineer at Tier-1 Systems, Inc. (Mountain View, CA) where she led the design and rollout of an evaluation harness now used in production across all Tier-1 retrieval-augmented generation deployments. From 2022 through the present, she has served as a Staff Machine Learning Engineer at Cortex Labs, contributing to the inception and current production status of the Cortex Inspect evaluation platform. Her work has been incorporated into three peer-reviewed publications, two issued patents, and the company's confidential production reproducibility handbook.

Specifically, Ms. Sharma's specialty qualifications align with the proffered position in the following material respects: she has independently authored production-grade evaluation suites that meet SOC 2 reproducibility standards (Tab D); she has led cross-team engineering reviews governing production-inference architecture (Tab E); she has contributed to peer-reviewed publications in the field of large-language-model evaluation (Tab F); and she maintains an active record of continuing technical education through participation in the NeurIPS Reviewer Program and the ACL Special Interest Group on Natural Language Generation (Tab G). The combination of degree credentials and progressive specialty experience meets — and materially exceeds — the minimum qualifications established for the position.

IV.  Legal Argument

The proffered position qualifies as a specialty occupation within the meaning of INA § 101(a)(15)(H)(i)(b) and 8 CFR 214.2(h)(4). Specifically, by virtue of the duties enumerated above and the corresponding entry requirements in Petitioner's standard occupation description, the position satisfies at least three of the four criteria enumerated in 8 CFR 214.2(h)(4)(ii): (A) a bachelor's or higher degree in a specific specialty is normally the minimum entry requirement for the position; (C) the position requires the theoretical and practical application of a body of highly specialized knowledge in machine learning, distributed inference, evaluation methodology, and statistical robustness; and (D) the position is sufficiently complex and specialized that it requires a person with at least a bachelor's degree in a directly related quantitative field plus progressive specialty experience.

The Beneficiary qualifies for H-1B classification by virtue of her U.S. Master of Science in Computer Science (concentration: Machine Learning) from Carnegie Mellon University, a degree program nationally recognized for producing graduates who command specialty occupation roles at the senior level; her admission to and successful completion of this program is independently documented in Tab H. The Beneficiary's combined credential-plus-experience qualification further satisfies 8 CFR 214.2(h)(4)(iii)(C), the alternative experience-credential equivalency provision, given that her progressive specialty experience substantially exceeds the six-year threshold for equivalency to a U.S. master's degree in the field.

The wage offered ($182,000 annualized) exceeds the level II prevailing wage for SOC 15-1221 in the San Francisco, CA MSA at the time of LCA certification, and the LCA has been certified by Petitioner's authorized signatory in compliance with 20 CFR 655.730 through 655.740. Petitioner's working conditions, public access file, and noticeposting obligations under 20 CFR 655.734 have been satisfied. Petitioner maintains the documentation required by 8 CFR 214.2(h)(4)(iv) and is prepared to produce it upon request.

V.  Conclusion and Request for Approval

Based on the foregoing, Petitioner respectfully requests that the Service Center approve this H-1B specialty occupation worker petition and grant Ms. Priya Sharma authorization to be employed by Cortex Labs, Inc. as a Senior Machine Learning Engineer for the requested period of October 1, 2026 through September 30, 2029. The petition is supported by the documentary evidence catalogued below and is, in Petitioner's judgment, complete and ready for adjudication.

Petitioner respectfully requests that any Request for Evidence issued in connection with this petition be directed to the undersigned counsel of record at the contact information provided below. Petitioner stands ready to respond to any such request within the time frame prescribed by the Service Center.

Respectfully submitted,

Exhibit List

• Tab A. Certified Labor Condition Application (LCA Case No. I-XXX-XXXXX-XXXXXX) and Department of Labor ETA-9035
• Tab B. Petitioner organizational documents, including Certificate of Incorporation, bylaws, and most recent audited annual financial statements
• Tab C. Detailed position description draft, including a duty-by-duty mapping to SOC 15-1221 occupational classification
• Tab D. Beneficiary curriculum vitae, with full employment history, supervised specialty experience, and project portfolio
• Tab E. Beneficiary credentials — Bachelor's diploma (IIT Madras), Master's diploma and transcript (CMU), plus credential evaluation in U.S. equivalency terms
• Tab F. Beneficiary production-engineering work product — code repositories, evaluation suite documentation, peer-reviewed publications list
• Tab G. Letters of attestation from Petitioner's Director of Applied Research and from an external senior reviewer documenting the specialty nature of the position and Beneficiary's qualifications
• Tab H. Petitioner maintenance-of-status documentation, if applicable, including prior I-797 approval notices and pay stubs reconciling the offered wage to actual compensation