Comment from Odyssey Marine Exploration, Inc.

Odyssey Marine Exploration, Inc. (“Odyssey”) appreciates the opportunity to respond to the Bureau of Ocean Energy Management’s (BOEM) Request for Information and Interest (RFI) regarding a potential mineral lease sale offshore the Commonwealth of Virginia. In November 2025, Odyssey submitted an unsolicited lease request to BOEM seeking a marine minerals lease sale that would provide an opportunity to explore and potentially develop Heavy Mineral Sands (HMS) deposits within a defined area of the U.S. Outer Continental Shelf (OCS). Through this RFI, BOEM has invited comments from interested parties regarding the proposed lease area and potential leasing process. Odyssey supports BOEM’s efforts to gather stakeholder input and conduct a transparent, science-based review of the proposed project. The comments provided in the attached submission reflect Odyssey’s perspective on the technical, environmental, and commercial considerations associated with the proposed lease area and are intended to assist BOEM in its evaluation of potential future leasing decisions. Odyssey also incorporates by reference its prior submissions to BOEM related to its lease request. Please see the attached comment letter for Odyssey’s full comments.