Comstock director-linked fund buys 424,559 shares

Q: Are the Comstock (LODE) insider holdings direct or indirect in this Form 4?

The shares in this Form 4 are reported as indirect holdings. Ownership is listed under Gratia Capital, with the nature of ownership coded as indirect, meaning the position is held through this related entity rather than directly by the individual director.

Comstock Inc. director Steven Yu-Tsung Pei reported indirect open-market purchases of Common Stock through Gratia Capital.

Filing Impact

(High)

Filing Sentiment

(Positive)How Sentiment works

Sentiment and the balance of points

Rhea-AI Sentiment reads the wording of the document, how positive or negative its language is on a 1 to 5 scale. The balance of points shown with the takes weighs what the document actually discloses, so the two can disagree, for example when a trial that missed its main goal is described in upbeat language.

How Sentiment works How the balance works

Form Type

Rhea-AI Filing Summary

Comstock Inc. director Steven Yu-Tsung Pei reported indirect open-market purchases of Common Stock through Gratia Capital. The filing shows two buys totaling 424,559 shares at prices between $3.375 and $3.425 per share. Following these transactions, 1,530,980 shares of Comstock common stock are held indirectly.

Insider Trade Summary

Net Buyer: 424,559 shares

Net Buy 2 txns

Insider Pei Steven Yu-Tsung

Role Director

Bought 424,559 shs ($1.44M)

Type	Security	Shares	Price	Value
Purchase	Common Stock	79,559	$3.425	$272K
Purchase	Common Stock	345,000	$3.375	$1.16M

Holdings After Transaction: Common Stock — 1,530,980 shares (Indirect, Gratia Capital)

Key Figures

Total shares bought: 424,559 shares Purchase on May 13, 2026: 345,000 shares at $3.375 Purchase on May 14, 2026: 79,559 shares at $3.425 +2 more

5 metrics

Total shares bought 424,559 shares Aggregate open-market purchases reported in Form 4

Purchase on May 13, 2026 345,000 shares at $3.375 Common Stock, indirect via Gratia Capital

Purchase on May 14, 2026 79,559 shares at $3.425 Common Stock, indirect via Gratia Capital

Shares held after transactions 1,530,980 shares Indirect Comstock common stock holding after May 14, 2026

Net buy direction net-buy of 424,559 shares transactionSummary netBuySellShares and netBuySellDirection

Key Terms

open-market purchase, indirect ownership, Common Stock, transaction code "P"

4 terms

open-market purchase financial

"transaction_action is listed as "open-market purchase" for both trades"

An open-market purchase is when an investor or a company buys shares on a public stock exchange at the going market price, rather than through a private deal. It matters to investors because these purchases change how many shares are available, can push the stock price up or signal confidence from large buyers, and often affect per-share metrics like earnings—think of it like someone buying lots of apples off a grocery shelf, reducing supply and potentially raising the price.

indirect ownership financial

"Each transaction is coded as indirect with nature of ownership "Gratia Capital""

Common Stock financial

"Both transactions involve the security title "Common Stock" of Comstock Inc."

Common stock represents ownership shares in a company, giving investors a stake in its success and a say in important decisions through voting rights. It is the most common type of stock traded on markets and can provide income through dividends, as well as potential for value growth. For investors, holding common stock means sharing in the company’s profits and risks.

transaction code "P" regulatory

"The filing uses transaction code "P" indicating purchases in open market"

FAQ

AI-generated questions and answers. How Rhea-AI works. Not financial advice.

What insider transactions did Comstock (LODE) report in this Form 4?

The Form 4 reports that an entity associated with director Steven Yu-Tsung Pei, Gratia Capital, completed two open-market purchases of Comstock common stock, totaling 424,559 shares, on May 13 and May 14, 2026, at prices slightly above $3.37 per share.

How many Comstock (LODE) shares were bought and at what prices?

Gratia Capital bought 345,000 Comstock common shares at $3.375 on May 13, 2026, and 79,559 shares at $3.425 on May 14, 2026. In total, 424,559 shares were acquired in open-market purchases reported in this filing.

Is the Comstock (LODE) Form 4 transaction a purchase or a sale?

The Form 4 discloses purchases only. Both reported transactions are coded “P” for open-market purchases, indicating that an entity associated with director Steven Yu-Tsung Pei, Gratia Capital, bought Comstock common stock rather than selling or disposing of shares.

How many Comstock (LODE) shares are held after these insider purchases?

After the May 14, 2026 transaction, the filing shows 1,530,980 Comstock common shares held indirectly. These shares are reported as owned through Gratia Capital, reflecting the position following completion of the disclosed open-market purchases.

Are the Comstock (LODE) insider holdings direct or indirect in this Form 4?

The shares in this Form 4 are reported as indirect holdings. Ownership is listed under Gratia Capital, with the nature of ownership coded as indirect, meaning the position is held through this related entity rather than directly by the individual director.

AI-generated analysis. How Rhea-AI works. Not financial advice.

Form 4 Insider Transactions: What Each Field Means →

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Accepted by SEC EDGAR 05/14/2026 - 05:41 PM

SEC Form 4

FORM 4

UNITED STATES SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP

Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934
or Section 30(h) of the Investment Company Act of 1940

OMB APPROVAL

OMB Number:			3235-0287
Estimated average burden
hours per response:			0.5

Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

Check this box to indicate that a transaction was made pursuant to a contract, instruction or written plan for the purchase or sale of equity securities of the issuer that is intended to satisfy the affirmative defense conditions of Rule 10b5-1(c). See Instruction 10.

1. Name and Address of Reporting Person^*

Pei Steven Yu-Tsung

(Last)

(First)

(Middle)

117 AMERICAN FLAT ROAD

(Street)

VIRGINIA CITY

NEVADA

89440

(City)

(State)

(Zip)

UNITED STATES

(Country)

2. Issuer Name and Ticker or Trading Symbol
Comstock Inc. [ LODE ]

5. Relationship of Reporting Person(s) to Issuer
(Check all applicable)

X	Director	10% Owner
	Officer (give title below)	Other (specify below)

2a. Foreign Trading Symbol

3. Date of Earliest Transaction (Month/Day/Year)
05/13/2026

6. Individual or Joint/Group Filing (Check Applicable Line)

X	Form filed by One Reporting Person
	Form filed by More than One Reporting Person

4. If Amendment, Date of Original Filed (Month/Day/Year)

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	3. Transaction Code (Instr. 8)		4. Securities Acquired (A) or Disposed Of (D) (Instr. 3, 4 and 5)			5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4)	6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
1. Title of Security (Instr. 3)	2. Transaction Date (Month/Day/Year)	2A. Deemed Execution Date, if any (Month/Day/Year)	Code	V	Amount	(A) or (D)	Price		6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	7. Nature of Indirect Beneficial Ownership (Instr. 4)
Common Stock	05/13/2026		P		345,000	A	$3.375	1,451,421	I	Gratia Capital
Common Stock	05/14/2026		P		79,559	A	$3.425	1,530,980	I	Gratia Capital

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned (e.g., puts, calls, warrants, options, convertible securities)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	4. Transaction Code (Instr. 8)		5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5)		6. Date Exercisable and Expiration Date (Month/Day/Year)		7. Title and Amount of Securities Underlying Derivative Security (Instr. 3 and 4)		8. Price of Derivative Security (Instr. 5)	9. Number of derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4)	10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)
1. Title of Derivative Security (Instr. 3)	2. Conversion or Exercise Price of Derivative Security	3. Transaction Date (Month/Day/Year)	3A. Deemed Execution Date, if any (Month/Day/Year)	Code	V	(A)	(D)	Date Exercisable	Expiration Date	Title	Amount or Number of Shares	8. Price of Derivative Security (Instr. 5)		10. Ownership Form: Direct (D) or Indirect (I) (Instr. 4)	11. Nature of Indirect Beneficial Ownership (Instr. 4)

Explanation of Responses:

	/s/ Steven Pei	05/14/2026
	** Signature of Reporting Person	Date
Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.
* If the form is filed by more than one reporting person, see Instruction 4 (b)(v).
** Intentional misstatements or omissions of facts constitute Federal Criminal Violations See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).
Note: File three copies of this Form, one of which must be manually signed. If space is insufficient, see Instruction 6 for procedure.
Persons who respond to the collection of information contained in this form are not required to respond unless the form displays a currently valid OMB Number.
* Form 4: SEC 1474 (03-26)

Source: View Original Filing on SEC EDGAR