No. Seniority and a technology stack may provide context, but the employer must establish special or advanced knowledge and a U.S. position involving it. The qualifying corporate relationship and foreign employment are also necessary.
Explain the engineering distinction
Describe the employee’s understanding of the organisation’s platform, processes or products and compare it appropriately with ordinary industry skills or other workers’ process knowledge. Use actual technical contributions and learning history. Knowledge need not be proprietary, but common programming ability should not be relabelled as specialised simply because the employee is experienced.
The failure mode is describing a career instead of a capability. Seniority, tenure and a list of technologies establish that someone is experienced, which is not the question asked. Hypothetical example: an engineer who built a company proprietary wafer-test scheduling system is described in the draft as a senior developer with extensive industry experience, and the specific system is not mentioned until the final paragraph.
The earliest signal is a description that would fit a colleague equally well. Explain the employee understanding of the organisation platform, processes or products and compare it appropriately with ordinary industry skills. Knowledge need not be proprietary, and common programming ability should not be relabelled as specialised because the employee has practised it for a long time.