"Auction date extended for ECD's sale of solar panel firm"

I had stopped paying attention to ENER, but saw this in the Detroit News:

"[E]nergy Conversion Devices Inc. said Monday it has extended by two weeks the auction date for the sale of United Solar Ovonic LLC, its manufacturer of thin-film photovoltaic solar panels."

Apparently, a company called Salamon Group wants to buy ENER for its net operating loss carryforwards:

"This offer is for up to 100% of all issued and outstanding shares of the Company. The offer is in exchange for up to 5 million shares of Salamon Group, Inc. (SLMU). Energy Conversion loss-carry forwards are over $1 billion USD."

It's not clear to me that this transaction would work. The IRS rules on NOLs impose significant limits on the ability to use them to offset taxable income in the event of an ownership change.