Comstock Inc (LODE)

[TMLonggun]

Am I correct in reading that Van Den Berg Management has filed announcing they have accumulated 22 M shares of CMI?

sc13g
"To be able to file a 13G instead of a 13D, the party must own between 5% and 20% in the company. It must also be clearly understood that the party acquiring the stake in the company is only a passive investor, and does not intend to exert control. If these criteria are not met, and if the size in the stake exceeds 20%, a 13D must be filed."

Ownership.

(a)
Amount beneficially owned: 21,363,727
(b)Percent of class: 25.29%
(c)Number of shares as to which the person has:
(i)Sole power to vote or to direct the vote:21,363,727
(ii)Shared power to vote or to direct the vote:None
(iii)Sole power to dispose or to direct the disposition of:21,363,727
(iv)Shared power to dispose or to direct the disposition of:None

So I think they had some before and then increased their position over the threshold where the need to report. My guess at least.