Contract analysis

I. Purpose and Scope The purpose of this memorandum is to identify and catalog all North American Specialty Minerals Council ("NASMC") quarterly conferences attended by personnel of Torchlight Mining Corp. ("TMC" or the "Company") from January 2017 through August 2021, which corresponds to the period alleged by the Antitrust Division of the United States Department of Justice ("DOJ") to constitute the operative consp

II. Background on NASMC The North American Specialty Minerals Council ("NASMC") is a trade association organized as a tax-exempt entity under Section 501(c)(6) of the Internal Revenue Code. NASMC is headquartered at 2300 Wilson Boulevard, Suite 400, Arlington, Virginia 22201. According to its publicly available charter documents and website, NASMC's stated mission is to "promote the responsible development, productio

III. Methodology A. Source Data and Collection The source data underlying this analysis was collected through the following means and from the following repositories: TMC Corporate Travel Records. TMC's corporate travel records for the period January 1, 2017 through August 31, 2021 were collected by Redstone Digital Forensics Inc. during the forensic collection conducted pursuant to Grand Jury Subpoena No. GJ-22-0194

IV. NASMC Conference Schedule — January 2017 Through August 2021 The following table sets forth the complete schedule of NASMC quarterly conferences during the relevant period, based on NASMC published conference programs, TMC internal files, and publicly available NASMC archive data. A total of nineteen (19) quarterly conferences were scheduled during this period. Seventeen (17) were held as in-person events, one (1

V. TMC Personnel Attendance — Conference-by-Conference Analysis A. Gavin Holt — Attendance Summary Gavin Holt served as TMC's Vice President, U.S. Specialty Minerals Sales from approximately January 2015 through his departure from the Company effective September 30, 2021. In that capacity, Mr. Holt was TMC's primary representative at NASMC conferences and was authorized to participate in NASMC's pricing-committee ses

VI. Known Competitor Attendance at NASMC Conferences A. Ridgecrest Minerals Inc. Carl Edgerton, Vice President of Sales at Ridgecrest Minerals Inc., has been identified in NASMC attendee rosters and in TMC internal emails as a regular attendee at NASMC quarterly conferences throughout the conspiracy period. Based on NASMC attendee rosters available in our files, Mr. Edgerton's name appears on the roster for at least

VII. Correlation Analysis — Conference Attendance and Alleged Coordination Events A. Overview of Correlation Methodology The correlation analysis set forth in this section is designed to assess the relationship between NASMC conference attendance and the alleged coordination events identified in the DOJ's investigation and in Calderwood & Harkness's internal investigation. The analysis is structured as follows: Each

VIII. Summary Table — NASMC Conference Attendance and Coordination Indicators The following master table consolidates the conference-by-conference data compiled in Sections IV through VII above. This table is intended to provide a single-reference overview of the attendance and correlation analysis for each NASMC conference during the conspiracy period. Key: R = Ridgecrest Minerals Inc.; P = Pinnacle Earth Resources

IX. Assessment of NASMC as a Coordination Vehicle Based on the analysis set forth in this memorandum, the following assessments can be made regarding the role of NASMC conferences in the alleged coordination scheme: First, NASMC conferences provided a recurring, predictable venue for in-person contact between Gavin Holt, Carl Edgerton, and Kevin Tsang outside of normal business channels. The quarterly cadence of the