A showing of past persecution creates a rebuttable presumption of a well-founded fear of future persecution. Id. at 1231. Persecution is an extreme concept, requiring more than a few isolated incidents of verbal harassment or intimidation, and mere harassment does not amount to persecution. Id. Tan failed to demonstrate that a reasonable factfinder would have been compelled to find that it was more likely than not that she would have faced persecution if returned to Indonesia. She failed to establish past persecution because none of the events to which she referred, including the robbery, the discrimination, and the problems at the department of motor vehicles, rose to the level of extreme conduct that persecution encompasses. See AR at 96, 103-04, 110-11; Sepulveda, 401 F.3d at 1231 (<HOLDING>). Indeed, she testified that she had never been
holding that harm must be sufficiently severe rising above mere harassment to constitute persecution holding that to constitute persecution harm must be more than harassment holding that to constitute persecution the harm must rise above mere harassment holding that persecution is an extreme concept requiring more than mere harassment holding that to constitute persecution the harm must be sufficiently severe rising above mere harassment