U.S. Immigration and Customs Enforcement (ICE) continues to use I-9 audits as part of its enforcement strategy. Evidence of this is the recent I-9 audit by ICE of Chipotle Mexican Grill Inc., a publicly-traded company which owns or operates approximately 1,100 restaurants and employs about 25,000 people, which audit triggered the dismissal of hundreds of employees. For further details regarding the Chipotle case, see http://www.huffingtonpost.com/2011/02/08/chipotle-immigration-raid_n_820295.html.