DISCLAIMER
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Blue Moon Metals - Letter to USC - Sep 22, 2026

Blue Moon raised C$156.25 million of equity in May 2026, after telling investors that Nussir’s remaining capital requirement would be met partly from “available undrawn amounts” under a US$140 million project finance package. The company had never signed final agreements for the US$50 million term loan or US$70 million stream.

“Prior to this deal we have not signed the final agreement with Hartree and Oaktree for our Nussir project financing … if we did, we would be fully financed.”

Christian Kargl-Simard, CEO, sponsored investor interview, 14 September 2026, approximately 4:39–5:05

This admission concerns the status of financing presented to the market before and during a prospectus offering. It also contradicts the CEO’s 11 August 2026 statement that Blue Moon was “fully financed to build all four mines…”.

We respectfully ask the Commission to:

  • obtain every Hartree/Oaktree term sheet, MOU, credit approval, definitive draft and board paper from 19 August 2025 onward, and establish what was legally committed on each disclosure date;

  • review the April 2026 offering record, including due-diligence responses supplied to the underwriters and the basis for describing US$120 million of unsigned financing as “available undrawn amounts”;

  • obtain Blue Moon’s deal communications, analyst-contact records, blackout lists and board materials concerning Springer and the Department of War-linked Elmet transaction;

  • identify recipients of advance information and review trading in Blue Moon securities and related instruments before the 14 September announcement; and

  • require prompt corrective disclosure if the Hartree/Oaktree project financing remains unsigned or unavailable on the terms previously promoted.

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