We agree with and adopt the well reasoned opinion of the district court. R.L. Inv. Ltd. Partners v. INS, 86 F.Supp.2d 1014 (D.Haw. 2000).

R.L. Investment Limited Partners argues for the first time on appeal that the INS’s new rules were impermissibly retroactive, that the Administrative Appeals Office’s (AAO) addition of new grounds for affirming the regional director’s denial of Wanxuan Zou’s petition violates the due process clause, and that the AAO is not an independent adjudicatory body entitled to render rules in an adjudicatory proceeding. However, we decline to consider these arguments because they were not *875 raised in the district court. See Bolker v. Comm’r of Internal Revenue, 760 F.2d 1039, 1042 (9th Cir. 1985).

AFFIRMED.