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Blue Moon Metals – Response to the Non-Response

August 13, 2026 – Earlier today, Blue Moon Metals CEO Christian Kargl-Simard hosted a cozy fireside chat with brokers where he dismissed our work. Given the context of that discussion, we anticipate Blue Moon’s response to our report will be poor.

Kargl-Simard refuses to acknowledge the established fact that the EFTA Surveillance Authority (ESA) has issued a Formal Notice for the revocation of Nussir’s PCA permit.

  • He then explicitly states that the Supreme Court's judgment applied only to Engebø, and had no bearing on Nussir. We reiterate that this case, pursued by the EU, was against the State of Norway for issuing the permits.

  • Not only did the court find that the permits were invalid – they also stated they “cannot... be repaired retrospectively”.

Kargl-Simard then reminded brokers that Nussir is a designated Strategic Project under the EU Critical Raw Materials Act (CRMA).

  • After receiving its designation: Nussir obtained an offtake agreement with Hartree for effectively all of the mine’s output.

  • Hartree has just signed up as a “leading participant” in the landmark EXIM-funded ‘Project Vault’ deal and reiterated a “long standing commitment to supporting American industrial end-users and manufacturers”. This explicitly disqualifies Nussir from retaining its designated Strategic Project status under CRMA upon reassessment, which is due prior to the commercialization of the mine.

Kargl-Simard also takes issue with our analysis of Springer and Apex. We reiterate that our assessment of the Springer feasibility was derived from “management best estimates” provided to the sell-side, and simply corrected for objective errors.

Lastly: brokers note that Blue Moon is planning various news-flow items for Springer and Apex over the next few months. This, we could have guessed.

Today’s report provides greater detail into our conviction and rebuts CEO Kargl-Simard’s poor response.

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