A pure dropship e-commerce model, which can run with almost no staff, is a difficult fit for EB-5's job creation requirement. A credible EB-5 e-commerce plan usually centers on in-house fulfillment, warehousing, or a customer service operation substantial enough to genuinely support 10+ direct jobs.
Building the Case for In-House Operations
If your model includes owning inventory and operating your own fulfillment (rather than 3PL or dropshipping), that creates real warehouse, packing, and logistics jobs that count directly. State explicitly why your model requires in-house staff rather than outsourced fulfillment, since a plan that describes a lean, mostly-outsourced operation will struggle to justify a large direct headcount.
Customer Service and Operations as Job Categories
Beyond warehouse staff, customer service representatives, marketing/growth staff, and operations management all count as genuine positions if they're real W-2 roles tied to your revenue scale — build out the full organizational structure rather than concentrating your job creation table narrowly on fulfillment alone.
Capital Deployment for a Digital-First Business
Warehouse or fulfillment center lease and build-out, technology platform investment, inventory financing, and working capital for marketing and payroll during ramp-up should all be itemized in your capital deployment schedule.
Revenue-to-Headcount Consistency
Your financial projections need to support the payroll implied by your job creation table — a headcount that requires substantially more revenue than your market analysis and financials project will undermine the plan's credibility under Matter of Ho's specificity standard.
This is a draft for your attorney's review — not a legal filing, and no immigration outcome is ever guaranteed.