QV GOLD PROJECT, YUKON

The QV Property in the Yukon Territory, which covers 16,335 hectares (40,000 acres) within the White Gold District in the Yukon Territory, about 70 kilometres south of Dawson City.  The QV project is contiguous to Kinross Gold’s White Gold project and hosts a similar style mineralization to the Golden Saddle deposit.

Comstock optioned the original QV property in 2010 from Shawn Ryan, a Yukon-based prospector responsible for the initial identification of two of the prominent gold discoveries in the White Gold District, Kinross Gold’s +1.0 million ounce Golden Saddle deposit on its White Gold project ,10 km to the south, and Kaminak Gold’s +5.0 million ounce Coffee project 40 km to the south.  The Company earned a 100% interest in the property in 2014 by making staged cash and share payments and completing exploration expenditures.

The QV Property is subject to a 2.0% Net Smelter Royalty (“NSR”) to the optionor.  The Company has the right to acquire 1.0% of the NSR for a payment of $2,500,000. Commencing June 22, 2015, the Company must also make annual cash advance payments of $25,000 to the optionor until the commencement of commercial production (the “Advance Royalty”). The Advance Royalty is deductible against the NSR.

The Company may pay the Advance Royalty in cash or by issuing common stock of the Company based on the average closing price of its shares in the 10 trading days prior to the due date of the Advance Royalty. On September 30, 2015, the Company and the optionor agreed to settle the two $25,000 annual cash payments due on June 22, 2015 and 2016 in return for the issuance of 400,000 common shares of the Company. On July 12, 2016, the Company received TSX approval to issue 200,000 shares with a deemed issue price of $0.125 to satisfy the $25,000 owing from June 22, 2015 and to issue 125,000 shares with a deemed issue price of $0.20 to satisfy the $25,000 owing from June 22, 2016. The common shares issued in satisfaction of the indebtedness were subject to a four month hold period from the date of issuance.

2010-2013 Exploration Work

Exploration by Comstock Metals Ltd. between acquisition in 2010 and 2013 consisted of the collection of 8,161 ridge and spur and grid soil samples, prospecting and geological mapping with coincident geochemical sampling, a 773 line kilometre airborne magnetic and radiometric geophysical survey, ground magnetic surveys and 32 induced polarization lines over the VG, Stewart and Shadow zones, 3,570m of small excavator trenching in 28 trenches, 3,005m of direct push and geoprobe sampling on the QV, Stewart and Shadow grids, an aerial drone survey over the VG zone, and 3,419m of diamond drilling in 17 holes on the VG zone.

Visible gold was initially discovered on the southern QV Project by Comstock Metals Ltd. on June 10, 2012 while conducting follow up prospecting of a gold in soil anomaly; an initial grab sample returned 16.28 g/t Au and 47 g/t Ag with anomalous bismuth, tellurium, mercury, molybdenum and lead. The VG zone consists of quartz ±carbonate veins, stockwork and breccia zones, as well as pyrite veinlets, including cubic pyrite and visible gold, associated with intense-quartz-carbonate-sericite (or possible illite) alteration, with albite, pervasive K-spar and hematite. Overall gold is associated with anomalous silver, mercury, bismuth, tellurium, molybdenum, antimony, and barium. This style of mineralization and alteration is analogous to that at the Golden Saddle deposit on the White Gold Project.

Trenching on the VG zone in 2012 delineated a 450m by 65m, 250° trending zone of gold mineralization. Trench results (reported as length along the trench, not true widths) include 3.52 g/t Au over 80m from QVTR12-6, 1.63 g/t Au over 95m from QVTR12-12, and 2.18 g/t Au over 85m from QVTR12-13. Drilling on the VG zone intersected true widths of 2.23 g/t Au over 42m in QV12-004, 1.45 g/t Au over 60m in DDH QV12-6, 1.03 g/t Au over 78m in DDH QV12-1, including 6.15 g/t Au over 5.6m, 1.36 g/t Au over 42.6m in DDH QV13-11 (275m down dip of the mineralized zone in the discovery trench, QVTR12-6), and 1.76 g/t Au over 42.3m in DDH QV13-12 (at the open ended western limit of the zone).

The drill program delineated an open ended 250°/20-30°N trending, near surface tabular body of gold mineralization at the VG zone with a strike extent of 325m, traced up to 275m down dip from surface, and averaging 35-40m true thickness. Mineralization remained open to the west, down dip and beneath the mafic hornblende gneiss to the east and further exploration and infill drilling was recommended with the most favorable drill orientation at 160°/- 60 to -70°.

Mineralization at the VG zone occurs as stacked or en-echelon lenses hosted along WSW, gently NNW dipping sheared zones (average orientation of 250°/20°N), which are common throughout the southern part of the QV property. The shear zones occur as one or more stacked and intersecting horizons. Subsequent brittle reactivation of these shallowly north-northwest dipping structures has included local fracturing of the adjacent felsic rocks, which has permitted the flow of hydrothermal fluid that caused sericite (illite) – pyrite alteration of the adjacent wallrock, and local gold mineralization. The primary host rock is biotite-feldspar(±augen)-quartz gneiss, which occurs structurally below a hornblende-biotite-feldspar-quartz gneiss.

The original soil anomaly over the VG zone on the QV grid consisted of a 2 km long (with a 500m gap through the hornblende gneiss unit) and up to 400m wide >10 ppb gold anomaly with maximum values of 395.6 ppb Au and 8.7 ppm Ag from a south facing slope, with better soil development than most of the property area. Infill soil sampling returned a maximum of 1277 ppb Au. At the VG zone and overall on the QV property anomalous gold in soils is associated with anomalous mercury, bismuth, tellurium, molybdenum, moderately high barium, antimony ±lead soil geochemistry.

Other significant mineralization on the QV grid includes the Pump, North Star adit, and GP2 zones which all appear to occur along 070°/steep south trending sinistral faults that offset the airborne magnetic high, similar to the sinistral fault that offsets the magnetic high at the Golden Saddle deposit of Kinross Gold Corporation. The VG zone occurs along the Telegraph Fault, the Pump zone and North Star adit zone along the Adit Fault, 600m south of the VG zone and the GP2 zone along the VG North Fault, 1.2 km north. The GP2 zone itself consists of a 2.16 g/t Au anomaly from bedrock along geoprobe line QVGP13-2.

At the Shadow zone (12 km north-northwest of the VG zone), two structures have been interpreted from magnetic data and surface mapping.  Low grade gold mineralization (0.33 g/t Au over 85m, including 0.9 g/t Au over 10m) is hosted by felsic intrusive rocks, of probable Jurassic age, along the northwest trending Spirit Fault which corresponds to a 2.7 km long northwest trending gold in soil anomaly, open to the southeast.  In addition, a 1.3 km long gold-in-soil anomaly, open to the northeast, parallels the ENE trending Shadow Fault (parallels the Telegraph Fault at the VG zone).  Initial bedrock interface sampling on the structures include results of 1.5 and 0.90 g/t Au. A second, possibly structurally related, east-northeast trending gold-in-soil anomaly extends through untested soil highs of 504 and 249 ppb Au in the central grid area. Maximum soil values on the Shadow grid include 514 ppb Au, 2.6 ppm silver, 33.9 bismuth, 9.3 ppm tellurium, 316.4 ppm arsenic, and 60 ppm Mo.

The Stewart zone, 5 km north-northwest of the VG zone, covers a 1.5 km long gold-in-soil anomaly, with a maximum value of 274.1 ppb Au, and anomalous bismuth, silver and tellurium ±molybdenum. The gold-.0in soil anomaly and low grade mineralization uncovered to date (0.13 g/t Au over 40m and 0.10 g/t Au over 30m in QVTR12-17, 0.48 g/t Au from a pit along QVTR12-9, and 0.12 g/t Au over 65m with a maximum of 0.42 g/t Au in geoprobe sampling) are associated with a magnetic low, along the southern margin of an intrusion of probable Jurassic age. The intrusion on the Stewart grid resembles the intrusion at Shadow and both appear to be related to the mineralized K-spar porphyry sills within the VG zone. The Stewart intrusion corresponds to an airborne potassium high anomaly and a thorium/potassium low in the Precision airborne survey, the same signature which characterizes the Jurassic aged Ten and Jual stocks, located 30 km northwest of the Stewart grid, and 20 km north of Shadow.

Mineral Resource Estimate

On July 8, 2014, the Company announced a National Instrument (“NI”) 43-101 compliant Inferred Mineral Resource of 230,000 ounces of gold (4.4 million tonnes at a grade of 1.65 g/t Au at a 0.5 g/t Au cut-off grade (COG)), at the VG zone, on its QV Project, White Gold District, Yukon Territory.  The VG Zone remains open along strike and down dip and other targets exist on the QV Project with potential for intrusion-related or orogenic gold mineralization.

From the 17 diamond drill holes (DDH) completed in 2012 and 2013, 16 (3,278 m) were used to construct a 3D resource model for the VG Zone. The model is comprised of 3 sub-parallel, geology-guided grade shells (at a nominal COG of 0.4 g/t gold). Assays within these zones were capped at 7 g/t au and composited into 2-meter lengths for estimation by block model. A 20 meter (Easting), 20 meter (Northing) and 10 meter (Vertical) block model was constructed using commercially-available software (GEMS^®). Grades for the blocks were estimated with Inverse Distance Squared (ID2) method using the modelled zones as hard boundaries. Density values for the model were assigned based on the average value from 63 density determinations carried out by Comstock using weight in air/weight in water method.

All reported Mineral Resources for the VG Zone are classified in the Inferred Mineral Resources category.  To limit the reported estimate to material considered potentially minable by open pit mining, a resource constraining pit shell was constructed using a gold price of US$1,300/ounce for gold, and cost and recovery assumptions used in previous NI 43-101 Technical Reports for the White Gold deposit 10 km to the south. Only the portions of the modeled zones at VG that fall within this pit are reported here as Mineral Resources at a COG of 0.5 g/t gold.

To demonstrate the relatively low sensitivity of the Inferred Mineral Resource estimate to changes in COG, tabulations at various COGs are listed below with the base case at a COG of 0.5 g/t gold highlighted.

The Technical Report (NI 43-101) was posted on SEDAR on August 21, 2014 and is available there and on the Company’s website for review.

2016 Exploration Work

On July 12, 2016, the Company announced it had commenced a surface exploration program on the QV project. The program was completed in early August and comprised 5.46 line km of IP/resistivity surveying at the VG, Shadow (12 km northwest of VG) and Stewart (5 km northeast of VG) targets, 359 GT Probe samples along 11 lines at the VG, Shadow and Stewart and a total of 451 soil samples collected at Shadow and Stewart.  Results of these surveys were instrumental in refining drilling targets for the subsequent RAB drilling program.  The size of the QV project was also increased by staking an additional 31 quartz claims to partially fill an internal gap within the property.

On August 30, 2016, the Company announced it had commenced a 2,500 m rotary air blast (RAB) drilling program at QV with an average planned hole depth in the 100 m to 150 m range.  The RAB drill program was designed to inexpensively and rapidly screen numerous prospective targets within the QV Property for subsequent follow-up with a diamond drill program.   The areas targeted for drilling included the VG deposit area, as well as the previously undrilled Shadow and Stewart targets.  The program, which consisted of a total of 2,423.15 m of RAB drilling in 34 holes, was completed in mid-November and results were disclosed in news releases on October 13, 2016, November 8, 2016 and December 19, 2016. The RAB drilling program has successfully demonstrated that the QV deposit is open to expansion to the southwest and northeast, and, that further drilling on the Shadow and Stewart targets is required to evaluate their potential.

Highlights of the 2016 RAB drilling program at QV include:

• Potential new zone discovered 150-200 m south of main VG deposit (3.05 m averaging 7.79 g/t gold starting at 4.57 m below surface in 16QVRAB001, October 13, 2016 news release)
• VG zone extended 55 m east of hole QV13-013 by holes 16QVRAB011& 12 on the south side of the Telegraph fault (16.76 m averaging 1.43 g/t gold and 18.29 m averaging 1.81 g/t gold, respectively, both from surface; October 13, 2016 news release)
• VG mineralized zone extended at least 200 m to the northeast on the north side of the Telegraph fault, as evidenced by 16QVRAB006 (35.05 m averaging 0.46 g/t gold starting at 59.44 m below surface; October 13, 2016 news release) and 16QVRAB014 (10.67 m averaging 1.65 g/t gold starting at 16.76 m below surface in 16QVRAB014 within a wider interval of 64.01 m averaging 0.52 g/t gold; November 8, 2016 news release). Holes drilled in this area ended in mineralization and diamond drilling will be required to delineate the zone’s thickness and grade characteristics
• VG deposit expanded 100 m down dip of hole QV13-12 and 45 m west of holes QV12-06,-08 by holes 16QVRAB017 (12.19 m averaging 5.53 g/t gold starting at 83.82 m below surface in 16QVRAB017, within a wider interval of 57.91 m averaging 1.89 g/t gold; November 8, 2016 news release) and 16QVRAB018 (18.29 m averaging 1.14 g/t gold starting at 85.34 m below surface; November 8, 2016 news release). Both holes ended in mineralization and the VG zone remains open to expansion to the west in this area
• Step out hole 16QVRAB024, drilled 750 m WSW along strike of VG deposit on an extension of the gold-in-soil anomaly, intersected 9.15 m averaging 0.326 g/t gold (see Map 1a)
• Initial drilling along a 460 m section of the Spirit fault at the Shadow zone intersected anomalous gold in a number of holes including 16QVRAB029 with 9.14 m averaging 0.662 g/t gold starting at 53.34 m down hole and ending in mineralization; planned depth was only reached in 1 of the 7 holes drilled at Shadow due to high groundwater flow (see Map 2)
• Three holes completed from a single pad on the eastern side of the Stewart zone intersected widespread anomalous gold ranging up to 0.318 g/t (see Map 3)

Significant RAB drill results for all holes from the 2016 program are presented below.

A total of 1752.58 m in 24 holes were completed at the VG zone (see Map 1and 1a) , 399.29 m in 7 holes at the Shadow zone (see Map 2) and 271.28 m in 3 holes at the Stewart zone (see Map 3).  Drilling problems related to high groundwater flow and/or heavily fractured bedrock resulted in a number of holes not being completed to target depth; 22 holes were stopped prior to reaching 100 m and 13 holes did not reach 50 m.

*This table includes results disclosed in October 13, 2016, November 8, 2016, and December 19, 2016 news releases

**Insufficient information is available to estimate the true thickness of these intercepts and, as such, the true thickness may be less than the down-hole length intercept reported above.

***Hole ended in mineralization

A total of 26 of the 34 holes drilled during the 2016 RAB program were also surveyed using an optical downhole televiewer. The televiewer collects gyroscopic and magnetically oriented high resolution imagery down the drill hole for the collection of in situ structural data. Interpretation and analysis of the televiewer data is ongoing and will help refine the geologic interpretation of the area to aid in future drill targeting.

Methodology and QA/QC

The Ground Truth Exploration Inc. RAB drill that was utilized for the 2016 RAB program has the capability of drilling a 90 mm hole to a depth of 100-150 m, depending on ground conditions.  The RAB drill rig is on a remotely-controlled track mounted platform which can be moved to nearby sites without helicopter support.  Each sample represents 1.524 m of length down hole.

The analytical work for the 2016 program was performed by Bureau Veritas Commodities Canada Ltd., an internationally recognized analytical services provider, at its Vancouver, British Columbia laboratory.  Sample preparation was carried out at its Whitehorse, Yukon facility.  All samples were prepared using procedure PRP70-250 (crush, split and pulverize 250 g to 200 mesh) and analyzed by method FA430 (fire assay with AAS finish) and AQ200 (aqua regia digestion and ICM-MS). The Company follows industry standard procedures for the work carried out on the QV Project, with a quality assurance/quality control (QA/QC) program. Blank, duplicate and standard samples were inserted into the RAB sample sequence sent to the laboratory for analysis. Comstock detected no significant QA/QC issues during review of the data.

Qualified Persons

Jodie Gibson, P.Geo. of Groundtruth Exploration Inc., a Qualified Person as defined by National Instrument 43-101, has supervised the exploration work and RAB drilling program at the QV Project and reviewed, verified (including sampling, analytical and test data) and compiled the data reported herein.  David A. Terry, Ph.D., P.Geo., a Qualified Person as defined by National Instrument 43-101, and an Officer and Director of Comstock, has reviewed and approved the scientific and technical disclosure relating to the 2016 QV exploration program.