Common use of NOLs Clause in Contracts

NOLs. None of the net operating loss carryforwards or tax credits of the Seller or its subsidiary ("NOLs") are subject to any current limitation resulting from an ownership change under Section 382 or 383 of the Internal Revenue Code of 1986 and neither the entering into of this Agreement nor the consummation of the Transaction will result in the occurrence of an ownership change upon the date hereof or the Closing Date.