Comstock Metals issues 283,784 Trident shares for debt

Executive Summary

• Comstock Metals Ltd. has completed a debt settlement transaction with Lambent Consulting Inc., a company owned by CEO Steven Goldman, to resolve $244,055 in principal and interest owed.
• The debt was settled via the transfer of 283,784 common shares in Trident Resources Corp., valued at $244,055 based on a closing price of $0.86 per share on November 10, 2025.
• The transaction is classified as a related party transaction under Multilateral Instrument 61-101; however, the company was exempt from obtaining a formal valuation and minority shareholder approval, relying instead on approval by disinterested directors.

Key Details

• Settlement Amount: $244,055, representing principal and interest on a loan originally disclosed in a news release dated August 31, 2023.
• Consideration: Transfer of 283,784 common shares in Trident Resources Corp.
• Valuation Basis: The number of Trident shares was calculated based on a closing price of $0.86 on November 10, 2025.
• Post-Transaction Holdings: Following the settlement, Comstock Metals holds a total of 541,591 Trident shares.
• Related Party Status: Mr. Goldman and Lambent Consulting are considered related parties under Multilateral Instrument 61-101.
• Regulatory Compliance: The company was exempt from formal valuation and minority approval requirements pursuant to sections 5.5(b) and 5.7(1)(e) of MI 61-101.
• Governance: The transaction was approved by the disinterested directors of Comstock Metals.
• Disclosure Timing: No material change report was filed 21 days prior to closing to allow for an expeditious closure of the debt settlement.
• Counterparty Relationship: Both Comstock Metals and Mr. Goldman are at arm's length to Trident Resources Corp.