SCHEDULE: MAK Capital Fund Sells Comstock Inc. Shares

MAK Capital Fund LP has reported the sale of a significant number of Comstock Inc. shares, reducing its stake to 6.7% while stating an intention to remain a large shareholder.

Summary

• MAK Capital Fund LP, along with MAK Capital One LLC and Michael A. Kaufman, have filed an amendment to their Schedule 13D.
• The filing details transactions over the past sixty days, primarily involving the sale of Comstock Inc. common stock by MAK Capital Fund LP.
• MAK Capital Fund LP sold a total of 124,521 shares between September 11, 2026, and September 15, 2026.
• These sales occurred at prices ranging from $2.5768 to $2.8549 per share.
• Following these transactions, MAK Capital Fund LP beneficially owns 5,065,656 shares, representing approximately 6.7% of the outstanding shares as of July 20, 2026.
• The reporting persons state that the sales were to rebalance the portfolio.
• They also affirm their intention to remain a large shareholder and that new appointees remain on the Issuer's board.

Sentiment

Score: 4

Explanation: StockSavvy.ai views this as a neutral to slightly negative sentiment due to significant sales activity by a major shareholder, despite assurances of remaining a large shareholder.

Positives

• MAK Capital Fund LP intends to remain a large shareholder in Comstock Inc.
• The new appointees to the Issuer's board of directors, as previously defined, remain in place pursuant to the Cooperation Agreement.
• The reporting persons disclaim beneficial ownership of securities they do not directly own, maintaining a clear stance on their holdings.

Negatives

• MAK Capital Fund LP has sold a substantial number of shares (124,521) in a short period.
• The sales represent a reduction in the fund's stake in Comstock Inc. from a previously higher percentage.
• The aggregate purchase price of the 5,065,656 shares beneficially owned by MAK Fund is approximately $15,073,749, implying a significant investment that is now being reduced.

Risks

• Potential for further sales by MAK Capital Fund LP, which could negatively impact the stock price.
• The stated intention to remain a large shareholder may be subject to change based on future portfolio rebalancing or market conditions.
• The cooperation agreement and board representation could be impacted if the fund's stake diminishes significantly further.

Future Outlook

MAK Fund intends to remain a large shareholder of the Issuer, and the New Appointees remain on the Issuer's board of directors pursuant to the Cooperation Agreement.

Management Comments

• MAK Fund has undertaken the sales reported in this Amendment No. 1 to the Schedule 13D to effectuate a rebalancing of its portfolio.
• MAK Fund intends to remain a large shareholder of the Issuer and the New Appointees (as previously defined and described in the Schedule 13D) remain on the Issuer's board of directors pursuant to the Cooperation Agreement (as previously defined and described in the Schedule 13D).

Industry Context

StockSavvy.ai notes that significant share sales by a major holder like MAK Capital Fund LP can signal a shift in confidence or a strategic portfolio adjustment. This is particularly relevant in industries with high volatility or where activist investor positions are common. The company's stated intention to remain a large shareholder, however, mitigates immediate concerns about a complete divestment.

Stakeholder Impact

• Shareholders may view the sales by a significant holder with concern, potentially leading to short-term price pressure.
• The continued board representation by new appointees suggests ongoing engagement and potential influence on corporate strategy.

Next Steps

• MAK Capital Fund LP will continue to hold its remaining stake in Comstock Inc.
• The New Appointees will continue to serve on the Issuer's board of directors.
• Further portfolio adjustments by MAK Capital Fund LP may occur.

Key Dates

Recommendation

The filing indicates a reduction in stake by a major shareholder, which is a negative signal. However, the stated intention to remain a large shareholder and the continued board representation provide some stability. Therefore, a 'hold' recommendation is appropriate, pending further clarity on the fund's long-term strategy and the company's performance.

Keywords

Comstock Inc., Schedule 13D, MAK Capital Fund LP, Shareholder, Securities, Common Stock, Portfolio Rebalancing, Insider Trading