Executive Summary / Key Takeaways

• Comstock Inc. has undergone a significant transformation, pivoting from traditional mining to become a leader in clean energy technologies, now operating two distinct, high-growth segments: Comstock Metals (solar panel recycling) and Bioleum Corporation (renewable biofuels).
• The company has dramatically strengthened its financial position, achieving a debt-free status as of September 30, 2025, following a successful $34.5 million equity raise and the elimination of all outstanding convertible and promissory notes.
• Comstock Metals is poised for exponential growth with its R2v3/RIOS certified zero-landfill solar panel recycling technology, which boasts industry-leading efficiency, low operating costs, and high-speed processing, with its first industry-scale facility expected to be operational and profitable in Q2 2026.
• Bioleum Corporation, now a separately funded entity, is advancing its "carbon-negative oil well" biofuel platform, targeting 200 million barrels of renewable fuel per year by 2035, supported by strategic partnerships, significant government incentives, and ongoing Series A financing.
• The strategic separation of these businesses, coupled with the monetization of non-core mining and real estate assets, aims to unlock substantial shareholder value by allowing each segment to pursue tailored funding and growth strategies in massive, rapidly expanding markets.

A Strategic Metamorphosis: From Gold Dust to Green Energy

Comstock Inc. (NYSE:LODE), incorporated in 2008, has evolved significantly from its origins in the historic Comstock Lode mineral district, known for its rich gold and silver deposits. Initially focused on traditional mining operations, the company embarked on a strategic pivot around 2017, exploring metal recovery and recycling. This journey culminated in a decisive shift towards clean energy technologies, establishing two high-growth platforms: Comstock Metals for solar panel recycling and Bioleum Corporation for renewable biofuels. This transformation is not merely a change in business lines but a fundamental reorientation towards systemic decarbonization and resource sustainability, positioning Comstock at the forefront of critical environmental and energy transitions.

The company's overarching strategy is to innovate and commercialize technologies that extract and convert under-utilized waste and natural resources into clean energy products. This involves leveraging its history in materials processing and its deep understanding of resource economics to address pressing global challenges. The strategic separation of its Metals and Fuels segments is a cornerstone of this approach, designed to maximize operational focus, attract specialized capital, and accelerate value creation in distinct, yet complementary, markets.

Comstock Metals: Forging a Zero-Landfill Silver Mine from Solar Waste

Comstock Metals is rapidly establishing itself as a leader in solar panel recycling, driven by a proprietary thermal delamination technology that offers a compelling solution to the escalating problem of end-of-life photovoltaic waste. The company's system is R2v3/RIOS certified, making it the only company in North America to offer a "certified proven zero-landfill solution" for solar panel recycling. This certification is a critical differentiator, providing customers with "peace of mind" that their environmental liabilities are "fully terminated" through a process that produces "100% commodity ready products."

The technological advantages of Comstock Metals are significant and quantifiable. The process "thermally destroy[s] at the molecular level" polymers and plastics without harming the valuable metals, ensuring clean, contaminant-free outputs. This results in "extremely low variable costs," reported at less than 7% of revenue or approximately $35 per ton, which management states is "lowest in the industry." The system boasts "high-speed processing," capable of handling "a panel every 7 seconds," enabling one production line to process "3.3 million panels or 100,000 tons per year." This efficiency translates into robust revenue streams, including upfront "tipping fees" of over $500 per ton from customers and "offtake revenues" of around $250 per ton from selling recovered materials. Notably, the silver-rich tailings consistently yield "30, 40, sometimes 50 ounces per ton," a concentration that "would make any Comstock miner proud." The company plans to further enhance value by investing in in-house silver refining, and eventually recovering all elements, including rare earth metals like tellurium, iridium, and gallium, with initial operations potentially starting by late 2027.

Comstock Metals operates in a market experiencing exponential growth. The U.S. market for end-of-life solar panels is projected to expand from approximately 3.5 million panels (100,000 tons) per year today to 33 million panels (1 million tons) by 2030. The company's strategic location in Nevada positions it to serve over half of this market, concentrated in California, Nevada, and Arizona. This geographical advantage, combined with its unique technology, creates a formidable competitive moat. While some competitors utilize smaller mechanical systems, they would require 20 such systems to match Comstock's capacity, incurring 2.5 times the capital expenditure and 25 times the operational expenditure. This stark economic disparity underscores Comstock Metals' superior competitive positioning.

Bioleum Corporation: Cultivating a Carbon-Negative Oil Well

Bioleum Corporation, Comstock's renewable fuels segment, has been strategically separated to accelerate its mission of producing extremely low-carbon renewable fuels from lignocellulosic biomass. Bioleum's technology platform is designed to convert under-utilized waste and purpose-grown energy crops into fuels like cellulosic ethanol, renewable diesel, and sustainable aviation fuels (SAF).

The technological differentiation of Bioleum is profound. Its refining solutions achieve "industry-leading yields of up to 125-140 gasoline gallon equivalents per ton of dry wood," which is "easily double our next competitor." Furthermore, these fuels boast "extremely low carbon intensity scores of 15," with the potential for carbon-negative production, particularly when integrated with Hexas Biomass Inc.'s XanoGrass. Hexas' energy crops are capable of producing "over 100 barrels of oil per acre per year," a significant leap compared to corn (10 barrels/acre/year) or soybeans (2 barrels/acre/year). This integration effectively creates a "carbon-negative oil well that never stops producing," transforming marginal agricultural lands into productive energy sources. Bioleum's R&D initiatives, including collaborations with NREL and the integration of the Madison facility acquired from Marathon Petroleum , are focused on advancing its technology readiness level (TRL 7), accelerating ASTM product approvals, and EPA pathway approvals. The Madison facility, a "state-of-the-art renewable fuel demonstration facility," is crucial, enabling Bioleum to produce up to two barrels of fuel per week and significantly shortening lead times for its planned commercial facilities.

Bioleum's competitive advantage stems from its superior yields, low carbon intensity, and unique feedstock strategy. While average biofuel technologies yield 40-60 GGE/ton, Bioleum's platform significantly outperforms. The ability to utilize abundant waste woody biomass and high-yielding perennial crops like XanoGrass provides a sustainable and cost-effective feedstock solution that competitors struggle to match. Bioleum plans to build a network of refineries in the U.S. to produce up to 200 million barrels of renewable fuel per year by 2035, aiming to meet half of the U.S. advanced biofuels mandate. This ambitious goal is supported by strategic partnerships, including Marathon Petroleum (MPC)'s $14 million investment at a $700 million valuation cap (which management views as a "floor"), and significant government incentives, such as a $3 million grant and a $152 million allocation of tax-free municipal bonds from Oklahoma. The company is also exploring international licensing opportunities, offering 6% engineering fees, 6% royalties, and a 20% equity stake without requiring capital contributions from Comstock.

Financial Strength and Strategic Capital Deployment

Comstock's financial performance in Q3 2025 reflects a company in transition, strategically investing for future growth while actively de-risking its balance sheet. The company reported an accumulated deficit of $365.46 million at September 30, 2025, indicative of its long-term investment in technology and growth. However, a "transformative quarter" saw cash and cash equivalents surge by $30.76 million to $31.71 million, including $12.43 million held by Bioleum. This was primarily driven by a successful $34.5 million gross equity raise, which netted $31.8 million and significantly expanded its institutional shareholder base. Crucially, Comstock achieved a "completely debt-free" status as of September 30, 2025, eliminating all convertible and promissory notes that had previously contributed to "endless sell pressure on the stock." This robust liquidity position, with net current assets of $21.3 million, provides a strong foundation for future operations.

Revenue for the three months ended September 30, 2025, decreased to $54,079 from $556,383 in the comparable 2024 period. This decline was primarily due to lower revenues from the Mining Segment following the termination of the Mackay Mining Lease in Q4 2024 and reduced decommissioning services in Comstock Metals. However, Comstock Metals' billable revenues are expected to be eight times greater in 2025 compared to 2024, exceeding $3.5 million, with proportional increases in 2026.

Cost of goods sold increased in Q3 2025 due to the ramp-up of the commercial demonstration facility for metal recycling. Selling, general and administrative (SG&A) expenses rose to $6.11 million in Q3 2025 from $3.18 million in Q3 2024, driven by higher employee-related costs, increased rent for new facilities, and accelerated payments for obligations like the Northern Comstock Joint Venture. Research and development (R&D) expenses also increased to $2.23 million in Q3 2025 from $1.44 million in Q3 2024, primarily due to collaborations with NREL and the Madison facility acquisition. The company holds $260 million in net operating loss carryforwards, which will shield the first $0.25 billion in future profits from cash taxes.

Outlook and Strategic Initiatives

Comstock's outlook for the remainder of 2025 and beyond is characterized by aggressive commercialization and strategic monetization.

For Comstock Metals, the immediate focus is on bringing its first industry-scale solar panel recycling facility online. Final permits are expected by Christmas 2025, with equipment arriving in Q4 2025, commissioning in Q1 2026, and the facility becoming operational and profitable in Q2 2026. This facility, costing an estimated $12.5 million (with $5.1 million in deposits already paid), is designed to process 100,000 tons of solar panels annually and is expected to be profitable at just 21% utilization. The company plans to build up to seven such facilities across the U.S. over the next five years, with site selection already underway for the second and third facilities, targeting operations by early 2027 and early 2028, respectively.

Bioleum Corporation is focused on completing its Series A financing, targeting at least $50 million in total proceeds by Q1 2026. This funding will support Bioleum's standalone operations, while project-level financing (over $200 million, including the $152 million Oklahoma bond allocation) will fund the construction of its first commercial biorefinery in Oklahoma. Site selection for this facility is expected to be finalized soon. Bioleum also plans to expand its integrated Madison pilot production capabilities to two barrels of fuel per week. The long-term vision is to achieve 200 million barrels (8 billion gallons) of renewable fuel per year by 2035, meeting half of the U.S. advanced biofuels mandate. The company is committed to spinning off Bioleum into a standalone public company after the Series A, with the expectation that Comstock shareholders will receive shares in both entities.

The Mining Segment is not a priority for direct production but is being actively evaluated for monetization. With gold prices exceeding $3,300 per ounce, there is significant strategic and financial interest in Comstock's assets, including the Dayton resource, which has an internal mine plan showing over $400 million in free cash flow at $3,000 gold. The company plans to invest $1-2 million in 2025 to upgrade and expand the Dayton Consolidated resource, aiming to define proven and probable reserves. Similarly, non-mining real estate and other strategic investments, including the Sierra Springs Opportunity Fund, are being actively marketed for sale, with over $50 million in proceeds anticipated from non-mining real estate and water rights by late 2026. These properties are attracting "major transactions" related to hyperscale data centers and off-grid renewable energy, despite past delays due to power grid bottlenecks.

Risks and Challenges

Despite the compelling growth narrative, Comstock faces several risks. The company has a history of recurring net losses and a substantial accumulated deficit, highlighting the capital-intensive nature of its ventures. While management believes it has sufficient funds for the next 12 months, there is no assurance of obtaining additional financing if needed, which could impact liquidity and raise going concern doubts. Operational expenditures could exceed expectations, and the market value of assets planned for sale could decline. The "valley of death" for TRL scaling companies is a recognized challenge, requiring relentless execution. Furthermore, customer adoption for solar panel recycling is sensitive to the final issuance of permits, and the ambitious timelines for facility deployment in both Metals and Fuels carry inherent execution risks.

Conclusion

Comstock Inc. is undergoing a profound transformation, strategically repositioning itself as a leader in two critical sectors of the clean energy transition: zero-landfill solar panel recycling and advanced renewable biofuels. The company's decisive actions to eliminate debt, secure substantial funding for its growth initiatives, and strategically separate its high-growth segments underscore a clear vision for value creation. With its technologically differentiated solar recycling solution poised for rapid scale and profitability, and Bioleum's innovative biofuel platform attracting significant capital and partnerships, Comstock is building a formidable competitive advantage in massive, expanding markets.

The commitment to technological leadership, evidenced by the R2v3/RIOS certification and industry-leading yields, combined with a disciplined approach to capital allocation and the monetization of non-core assets, positions Comstock for a compelling future. While execution risks and the inherent challenges of scaling new technologies remain, the company's strategic clarity, strengthened balance sheet, and robust market opportunities suggest a significant upside potential for investors who recognize the long-term value in its dual-engine ascent towards a decarbonized and resource-independent economy.