Omtammot LLC filed a joint plan of reorganization for Industrial Enterprises of America, Inc. and its subsidiaries in the US Bankruptcy Court on November 21, 2012. Under the plan, administrative claims and priority tax claims and non-tax priority claims will be paid in full in cash. Existing IEAM interests and non-IEAM interest's holders will retain their respective interests in the reorganized debtor.

Prepetition lender secured claims will be paid, in full satisfaction, the new secured note. IEAM general unsecured claims will be paid in full in cash. Subsidiary general unsecured claims will be paid 30% of the allowed claim in cash.

Subordinated claims will be paid on a pro rata number of shares of Common Stock in reorganized debtor. The debtor and its subsidiaries will continue to exist after the effective date as separate legal entities. The plan will be funded through cash in hand and issuance of New Secured Note.