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This article/video is a continuation of my big Comstock Write-up, since that lacked the SSOF deep dive because it was a smaller part of the investment thesis at the time, and now, due to various macro/local developments and Comstock tripling down on SSOF, it has become a crucial part of the thesis, which is why I wanted to really understand it.
This is a video/article hybrid, and you get most out of it by consuming both. You won’t see/hear everything that’s in the video from reading the article, and I won’t read everything that’s in the article during the video or look at every link.
Video Timestamps:
00:00 Introduction
Corporate developments:
02:46 Stock price, Mining Asset Sale
07:25 New board members added. Caused by shareholder activism from Institutional investors
11:30 Heavy Insider buying
13:40 New Management equity incentive plan
SSOF+Comstock Real Estate Deep Dive:
16:40 Ownership, Power agreement, Future capital needs
22:10 How much has Comstock invested in SSOF so far?
24:20 Breakdown of all SSOF and Comstock’s Land/Real Estate assets
38:05 Monetization value based on various statements from Comstock
46:25 Timing of Monetization, Corrado’s loan, QOZ Cap gains expiration
51:40 Comparing with adjacent transaction values, Silver Springs land prices, and data center land average pricing
1:01:49 Bullish regional/local developments supporting higher monetization value
1:09:14 Evaluating Site 1 as Data Center land
Metals Update:
1:16:02 Recent progress on commissioning, domestic tailings offtake, timeline, feedstock
1:21:00 Timeline, Ramp-up, achieving “machine” and corporate-level profitability
1:34:00 Capex validation, glass upgrading + new glass offtake
1:39:45 Advanced Metals recovery
1:41:38 Facility 2, Future facilities
1:44:47 Comparison with competitors, Solarcycle’s progress
1:50:05 New arrangement with Metals president
The rest:
1:52:30 Green Li-Ion: In production, DOE grant potential
2:02:46 Bioleum: Unfortunate
2:11:45 Closing thoughts and my positioning
Video Materials/Article:
General updates:
75.9 million shares as of May 27th, 2026
Market cap = $311 million
Cash $41.3 million as of May 27th, 2026 + $20 million arriving soon if the mining closes
At the end of Q1, cash was $53 million, and $3.9 million of it was Bioleum
In the near future, Comstock gets another injection of cash from the closing of their sale of mining assets:
$20 million cash and 2 million shares of Mackay when it closes
Closing is not certain “Obviously, we need to close on the mining assets and put $20 million of cash in the bank. People may yawn at that, because they may believe it's a foregone conclusion. We don't, we want to get the money in the bank, we want to close assets, right?” - CEO said this in a presentation on 9.7
Mackay shares have been trading in the range of around CA$2-4 (value range of US$2.8-5.6 million), and the stock price of Mackay reacted positively to the acquisition announcement
Given the positive response of Mackay stock, US$62 million cash on the balance sheet, and a new drilling program announced in the Comstock District, closing of the acquisition does seem very likely.
$7 million within 18 months, of which $2 million could be shares.
If they decide to mine within 7 years or get bought out for +$500 million, Comstock gets another $10 million contingent payment
1.5% royalty that Mackay can buy back for $3.5 million or $7 million if the contingent payment doesn't happen.
Comstock reduces costs by $1.5 million annually.
Max Final Amount 20+7+4(2 million*US$2per share)+10+3.5=$44.5 million
Minimum final amount apprx $27 million in cash + 2 million Mackay shares
Corporate developments:
3 new board members joined post-capital raise, and 2 old ones are leaving in 2027.
These board members are the result of shareholder activism by large institutions that bought heavily in the company's 2 recent capital raises, particularly MAK Capital and Gratio Capital, which have taken significant positions in those raises.
We are grateful for the constructive engagement of MAK Capital and Gratia Capital, whose thoughtful input has contributed to building a stronger board.
These appointments, reached through constructive dialogue between the Company and its significant shareholders including MAK Capital Fund LP and Gratia Capital LLC, reflect the Board’s commitment to governance excellence commensurate with Comstock’s evolution into a leading solar panel recycling and metals recovery company.
2 of the 3 new board members have already bought on the open market:
Steven Pei, the Chief Investment Officer and founder of Gratia Capital, made 2 huge purchases for ≈ $3.9 million
Robert Spence, whose specialty is metals recycling and refining, was appointed Chair of the Audit and Finance Committee and the Compensation Committee, and he bought for ≈ $97k.
Other insiders have been buying as well, such as the CEO, one of the old directors, and the CFO
Hood River Capital went from 1.8 million shares on September 30th 25 to 6.3 million on 15.5.2026. 8.48% of Comstock. They started their position by participating in the August 25 cap raise.
2026 EQUITY INCENTIVE PLAN:
I’d like to thank you for approving overwhelmingly some shares to compensate management. Comp committee has worked its butt off for the last two months. And there’s three things I can tell you. Our objective, our stockbased compensation is performance-based. What performance? The exact objectives that we disclosed and I reviewed with you. If we don’t achieve those objectives, we’re not getting compensation. If we achieve those objectives, we’re getting the compensation. Okay? And it’s tied to appreciation in the share price. If we grow the value of this company by hundreds and hundreds and hundreds of millions, said it three times, then we will vest some of that compensation. And if we don’t, we won’t. So it’s performance-based, but it’s um stockbased so that we’re aligned with the shareholders. We only make money if we’re making the shareholders money first. And we have a three-year plan. So, if we’re not around at the end of that third year, we’re not getting anything either. There’s no like, you know, mini league vesting here. You got to get to the finish line to achieve it. And we heard that from you. We heard that from many shareholders, especially some of our new shareholders. Why doesn’t management have more stock? Why isn’t your compensation more aligned with the performance of the stock? We addressed it head on.
I didn’t find details on how exactly they need to grow the value by hundreds and hundreds of millions to get this compensation in the 14A: LINK
For purposes of the 2026 Plan, performance goals mean any objective or subjective goals the administrator establishes. The 2026 Plan includes a non-exhaustive list of example performance measures that may be used.
The compensation committee seems to be responsible for determining the performance goals, and the new director rammed through by MAK Capital is the chair of that committee.
SSOF and Comstock real estate DEEP DIVE
SSOF ownership was 40.66% as reported in the Q1 call
All advances were finally converted at a cheap valuation.
They need to put in $9.5 million, of which $5 million has already been spent (reflecting $41.3 million in cash), to extinguish SSOF obligations and reach 51% ownership.
“As of the last quarter, we had about 9 and a half million to go to extinguish the obligation that Sierra Springs has. And we killed two birds with one stone by doing that. We get 51% of the entity. So, more than half of that has already been paid. We have a little bit to go. We’re keen to get it done because we’re getting a lot of outside interest now and we want to have our house in order. What does that mean? The obligations are gone. The platform is free and clear and we’re working with third parties to post the bonding that ensures that the power comes.” - annual meeting
“So 4.5 million to perfect the ownership of SSOF still needs to be paid.” - annual meeting
The power company wants cash collateral because Comstock doesn’t have a credit history/cash flow, etc. Comstock is negotiating with 3rd parties to do the bonding so they won’t have to use their own cash.
“Entered into a guaranty agreement with Great Basin Gas Transmission Company supporting an initial surety arrangement of $22 million increasing to $54.0 million by December 31, 2027, which secured power equivalent to 250-300 megawatts and supporting the high value monetization plan of our Nevada real estate investments.”
Comstock being the main funder of SSOF, and this power arrangement being between Comstock and the power company(not SSOF) gives Comstock immense leverage over SSOF
The CEO just said on the 9.7 presentation that they have finalized ownership: “It is also a little more complex in that perfecting that asset required us first to secure full ownership of all the lands, which we've done”. I still can’t find enough acres in public sources (next segment), but maybe there is a lag or something.
Many parcels of land that in early June (when I started researching this) had been listed with a different owner(presented as part of SSOF by Comstock at the time) now are listed as SSOF as the owner
Ownership calculations
“On March 26, 2026, all advances, totaling $15,150,000 were contributed in exchange for 23,307,692 shares of SSOF common stock at $0.65 per share. On March 30, 2026, the Company subscribed to and invested an additional $2,000,000 for 3,076,923 additional shares of SSOF common stock, also at $0.65 per share. These investments increased the Company's ownership to 40.66%” Q1 report https://seekingalpha.com/filing/292674859
$0.65 per share. Very cheap valuation considering everything. Likely only possible due to Comstock’s leverage.
In 2025, Comstock invested $650,000 in SSOF for 361,111 shares at $1.80 per share.
How much has Comstock sunk into SSOF so far?
2019-2024 $7,850,000 for 10,875,000 shares at a price of $0,72 per share
2025 = $650,000 at $1.8 per share
2026 = $2 million at $0.65 per share
$15.15 million advances converted to shares at $0.65
The Goal: Move from 40.66% to 51% ownership.
The Investment: $9,500,000 in new cash.
New Shares SSOF must issue:19,524,695 $
The Valuation Per Share:0.4866$ per share
= in total $35.15 million sunk cost
On top of this, Comstock would need to provide cash collateral for the power agreement if a 3rd-party bonding agreement is not reached.
Breakdown of SSOF and Comstock land/real estate assets
All the above combined is 2646 acres. But this next slide actually puts data center land at 1373+ AC(2777 AC in total).
Sierra Springs Opportunity Fund, Inc. owns 2500 acres[10,1 square kilometers] of land in Silver Springs. It owns and operates the Silver Springs Regional Airport. It owns 600 Lake Avenue with a 140,000 square foot manufacturing facility and a 7,500 square foot demonstration facility. It owns 1,800 to 1,900 acre feet of water rights in Silver Springs.
Comstock Inc. or its subsidiaries own 258 acres adjacent and contiguous with most of those acres and about 300 acre feet of water rights. That assemblage is powerful.
Comstock stepped in to extinguish part of the obligation that was taken on to acquire all those lands by Comstock certainly as an investor and the Sierra Springs investors together. So once we make the final payment that Tom was referring to, we own 51%. - annual meeting quote
SSOF also secured the rights to thousands of developable acres of land and other assets, including an agreement to purchase Comstock’s Silver Springs properties and water rights, all within the immediate proximity of the Tahoe Reno Industrial (TRI) Center.
Some of the Site 1 parcels are owned by DOWNTOWN SILVER SPRINGS LLC and DOWNTOWN SILVER SPRINGS II LLC, which are listed as subsidiaries of Comstock, not SSOF.
16) Downtown Silver Springs LLC, a Nevada limited liability company
Some properties from site 1 are still owned by individuals(such as (link), but most are in the hands of SSOF and Comstock subsidiaries:
20 + 270 + 226.65 + 19.62 + 18.73 + 36.45 + 159.61 + 38.20 + 98.40 + 0.10 = 887.76 acres for Site 1 now listed as owned by SSOF or Comstock with total size of 1007 acres.
Airport Land is owned by the County, and SSOF owns:
SSA’s listed assets include: • all fixed assets and equipment pertaining to the airport • Inventory and finished goods • Seller’s Lease Agreement with Lyon County, dated March 21, 2019 • Contracts, obligations and other agreements related to the airport • Certain real property of Seller located in Lyon County, Nevada • Trademarks, know-how, licenses, claims or 3rd party causes of action, records and goodwill”
These 4 total 257,63 acres, while Site 2 is supposed to be 244 Acres.
This was around 25% of the article/video. The remaining 75% is behind a paywall and covers the rest of the SSOF Deep Dive, Metals update, Green Li-Ion update, and Bioleum update:
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