Usually the petitioner, or the employer company files for a H-1B amendment for each of its H or L employees. However, USCIS’ Aleinikoff policy memorandum (8-22-96) regarding amendment of H-1B petitions states that “changes in the ownership structure of the petitioning entity generally do not require the filing of a new or amended petition if the petitioning entity continues to remain the alien beneficiary’s employer, provided the new owner(s) of the firm assumes the previous owner’s duties and liabilities...” This has been interpreted by USCIS Adjudications to apply to acquisition of discrete functional components or divisions of companies. An amendment (10/30/00) to INA §214 (c) provides that “[a]n amended H-1B petition shall not be required where the petitioning employer is involved in a corporate restructuring, including but not limited to a merger, acquisition, or consolidation, where a new corporate entity succeeds to the interests and obligations of the original petitioning employer and where the terms and conditions of employment remain the same but for the identity of the petitioner.”