Quite possible. Especially given how weak the index appears today. 22.60's went by the wayside more easily than I thought. The rally back was quite feeble before the downturn resumed.
Have been waiting quite a while for GDX to roll over. For weeks now, it has expended lots of buying energy just to stay in place. Exhaustion finally setting in today.
Will wait to see the magnitude of any bounce tomorrow. If GDX cannot regain 22.62, then the low 21's looks like the next destination.