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Correspondence 0001437749-24-032796 from Comstock Inc. (LODE)

Comstock Inc.
Date: Oct. 31, 2024 · CIK: 0001120970 · Accession: 0001437749-24-032796

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File numbers found in text: 333-282814

Date
October 31, 2024
Author
Corrado DeGasperis
Form
CORRESP
Company
Comstock Inc.

Letter

VIA EDGAR Securities and Exchange Commission Comstock Inc. Registration Statement on Form S-3 Originally Filed: October 24, 2024 File Number: 333-282814

Dear Mr. Richie:

On behalf of Comstock Inc., a Nevada corporation (the “Company”), and pursuant to Rule 461 under the Securities Act of 1933, as amended, I respectfully request acceleration of effectiveness of the above-referenced registration statement for Monday, November 4, 2024, at 4:00 p.m., Eastern time, or as soon thereafter as practicable. In connection with the foregoing, the Company hereby acknowledges that:

Should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

For purposes of Rules 460 and 461, there is no underwriter.

Please confirm the date and time of effectiveness of the registration statement to our counsel, Clyde Tinnen at Foley & Lardner LLP, at (414) 297-5026.

Very truly yours,
Comstock Inc.

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CORRESP
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	lode20241030_corresp.htm

COMSTOCK INC.

October 31, 2024

			VIA EDGAR

			Securities and Exchange Commission

			100 F Street, N.E.

			Washington, D.C. 20549

			Attn: Ben Richie

			Re:

			Comstock Inc.

			Registration Statement on Form S-3

			Originally Filed: October 24, 2024

			File Number: 333-282814

Dear Mr. Richie:

On behalf of Comstock Inc., a Nevada corporation (the “Company”), and pursuant to Rule 461 under the Securities Act of 1933, as amended, I respectfully request acceleration of effectiveness of the above-referenced registration statement for Monday, November 4, 2024, at 4:00 p.m., Eastern time, or as soon thereafter as practicable. In connection with the foregoing, the Company hereby acknowledges that:

			•

			Should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

			•

			The action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

			•

			The Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

For purposes of Rules 460 and 461, there is no underwriter.

Please confirm the date and time of effectiveness of the registration statement to our counsel, Clyde Tinnen at Foley & Lardner LLP, at (414) 297-5026.

			Very truly yours,

			Comstock Inc.

			By:     /s/ Corrado DeGasperis

			Name: Corrado DeGasperis, Executive Chairman & CEO