SecProbe.io

February 6, 2025
Nils Ollquist
Chief Executive Officer
Brookmount Explorations, Inc.
1 East Liberty Suite 500
Reno, NV 89501
Re:Brookmount Explorations, Inc.
Amendment No. 4 to Offering Statement on Form 1-A
Filed January 13, 2025
File No. 024-12392
Dear Nils Ollquist:
            We have reviewed your amended offering statement and have the following
comment(s).
            Please respond to this letter by amending your offering statement and providing the
requested information. If you do not believe a comment applies to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your offering statement and the information you
provide in response to this letter, we may have additional comments. Unless we note
otherwise, any references to prior comments are to comments in our September 18, 2024
letter.
Amendment No. 4 to Offering Statement on Form 1-A filed January 13, 2025
Cover Page
1.Your disclosure indicating that an offering of up to 100,000,000 common shares at an
estimated price range per share of $0.02 to $0.06 per share, assuming the offering
price is $0.02 per share, will result in gross proceeds of up to $500,000.00, before
deduction of offering expenses, assuming all shares are sold, appears an incorrect
calculation. Please revise or advise.

February 6, 2025
Page 2
Summary of the Offering
Termination of the Offering, page 5
2.You indicate the offering will conclude upon the earlier of the sale of all 200,000,000
shares or one year after the date of this offering circular. Please reconcile this with
disclosure elsewhere that you are offering 100,000,000 shares.

Selling Shareholders, page 15
3.In your tabular disclosure of your column "Total Number of Shares to be Offered for
Selling Shareholders Account" the number of shares to be offered does not equal
25M. For example, the shares offered by Makarios Partners LP does not appear to be
correct. Please revise or advise.
Dilution, page 18
4.We note you used $47,868,000 for total assets and $12,500,000 for intangible assets –
land usage right to derive net tangible book value as of August 31, 2024.  These
numbers do not agree to the Unaudited Consolidated Balance Sheet as of August 31,
2024 on page F-1, which shows $49,138,000 for Total assets and $11,983,000 for
Land usage rights.  Please advise or revise accordingly.
Use of Proceeds, page 21
5.The amount of Gross Offering Proceeds in the 50% and 25% columns of your table do
not appear to be correct. Please revise or advise.
Description of Properrty
Talawaan Property, page 25
Please revise your description of property to disclose your Joint Operating Agreement
and its Amendment filed as Exhibits 6.2 and 6.3 to this 1-A, including all material
terms. For example, it appears the agreement and its amendment contain the
following:

•For your consideration of $500,000 you acquired 70% equity ownership, with
30% retained by your Indonesian partner, and you have an option to acquire 100%
for certain other consideration.
•Cash is held by your Indonesian partner.
•Your Indonesian partner has a 25% Royalty on Net Profit Generated.
•The Koperasi license is currently set to expire in April 2025, and your Indonesian
partner has agreed to endeavor to extend the license.
•The current Koperasi license covers 10 hectares of the property, and your
Indonesian partner has agreed to take all necessary actions to expand the Koperasi
license area.

Please revise to disclose material terms of your license agreement and any
amendments. Also provide an update on the Koperasi license, and any renewal, and
what acreage the current Koperasi license covers (e.g., 10 or 50 hectares) and any 6.

February 6, 2025
Page 3
impact that could result from an inability to renew the license or expand the acreage
of such license on your operations. See Item 1304 (b)(1)(iii) of Regulation S-K.
Management's Discussion and Analysis of Financial Condition and Results of Operations
Private Offering of Common Stock, page 40
7.We note your disclosure that, on April 3, 2024, you offered and sold a total of
13,750,000 shares of common stock in a private offering to accredited investors under
Rule 506 (b) under Regulation D at price of $0.02 per share, for total proceeds of
$275,000, and that, on November 19, 2024, you closed an additional private offering
of 8,750,000 shares of common stock to accredited investors under Rule 506 (b) under
Regulation D at price of $0.02 per share, for total proceeds of $175,000. We note that
this amounts to $450,000 in total proceeds during 2024. This does not appear to be
consistent with your disclosure at Item 6(c)(1) of Part I of Form 1-A, which reflects
aggregate consideration for which the securities were issued of $500,000 within one
year. Please revise or advise.
Compensation of Directors and Executive Officers, page 42
8.Please provide updated director and executive officer compensation for your
last completed fiscal year. See Item 11 of Part II of Form 1-A.
Consolidated Financial Statements for the Quarters Ended August 31, 2024 and 2023
9. Events After the Reporting Period, page F-12, page F-12
9.We note your response to prior comment 9.  We re-issue the comment.  Your
Unaudited Consolidated Statement of Changes in Stockholders’ Equity on page F-3
shows 113,725,869 shares issued and outstanding as of August 31, 2024.  We also
note you disclosed 136,475,869 common shares issued and outstanding as of January
2, 2025 on various pages, including page 5.  Please revise Note 9 on page F-12 to
address the additional 22,750,000 common shares issued after August 31, 2024.
            Please contact Steve Lo at 202-551-3394 or Kimberly Calder at 202-551-3701 if you
have questions regarding comments on the financial statements and related matters. Please
contact Liz Packebusch at 202-551-8749 or Kevin Dougherty at 202-551-3271 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation
cc:Joe Laxague