Comstock Inc (LODE)

[NJPortfolioManager]

Okay, now before everyone starts getting excited about all of the "insider selling" going on here, you need to remember one thing. Many (if not most) publicly traded companies have "windows" set by management or the board during which insiders (directors and/or executives privy to non-public information) can sell portions of their shares. Usually this is done during standard pre-set timeframes throughout the year (like for instance, after publicly announcing quarterly results), or it may be within a prescribed timeframe before material news is made available to executives/directors (i.e. results of reports, drill results, etc). This is done to ensure that the insiders are compliant with SEC rules and regulations surrounding acquisition and disposition of shares by people demmed as "in the know".

For this reason, it is not rare to see multiple insiders selling portions of their holdings at the same time. It certainly does not always mean that something must be wrong or that they are trading on non-public info. In fact, since that is illegal, it is highly unlikely that a bombshell of bad news is on the immediate horizon. This would be an obvious violation.

Also, Jolcover's company, San Lucas Mining, still owns 2,800,000 shares, and Scott himself still owns 19,000,000. He is still clearly tied to this company in a BIG way, and this recent sale only amounts to 4% of his GSPG stock. Many people on this board and others who are extremely bullish on GSPG have routinely bought and sold more than 4% of their core position many times over. Not a big deaL, in my opinion.