This is IBM's Motion for an Order Converting the Debtors Chapter 11 Bankruptcy Cases to Cases Under Chapter 7 of the Bankruptcy Code [PDF], as text.
SCO is bleeding money, IBM tells the court, and it's had plenty of time to try to file a reasonable plan, but it has failed. SCO has told the court repeatedly that deals were just around the corner from finality, but no deals have ever materialized. The most recent claim was that prospective buyers/investors would materialize as soon as the appeal was filed. "However," IBM tells the court, "the Debtors have not been overwhelmed with prospective purchasers since the filing of their appeal in the Novell Case." The only reasonable course for the court now, IBM suggests, and the only legally appropriate course, is to convert the cases to Chapter 7 and let an impartial trustee take over.

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