Here are the essentials of KWG's arguments as regards to the "RR" claims. The intention of staking was related to to developing Big Daddy. Cliffs cannot use the easement request as a process to indirectly 'expropriate' the minority joint-venturer (in BD) in order to prefer its personal interest (BT)... Interesting point to say the least!

From the MD&A (my underlines):

To be able to continue to earn its interest in the Big Daddy deposit, KWG solicited an equity investment from Cliffs Natural Resources Inc. ("Cliffs"), which then became a 19.9% shareholder of KWG and nominated a representative to the KWG Board of Directors. KWG soon afterward purchased an existing underlying royalty interest in the area’s deposits and formulated a plan to stake claims along a series of sand ridges to provide the Big Daddy joint venture with exclusive mineral title to land over which its chromite might be equipped for further exploration and development. A technical assessment of these claims was then completed to provide a data base of geotechnical characteristics and glacial till sample profiles. The value of this work was accepted for assessment credit and an application is now being made to bring the claims to lease.

Recently, Cliffs has made application under the Public Lands Act for an easement to build a road for the purpose of developing Black Thor, on the claims KWG is bringing to lease for the purpose of making economic the Big Daddy joint venture’s undertakings. KWG had previously completed a preliminary economic assessment of the Big Daddy project to comply with the requirements of the Ontario Securities Act for public disclosure of the discovery’s economic merits. The Cliffs application to the Ministry of Natural Resources, which administers the Public Lands Act, was referred to the Ministry of Northern Development and Mines, which administers the Mining Act, and under the provisions of which KWG staked the claims and conducted assessment work. The Ministry of Northern Development and Mines then referred the matter to the Mining and Lands Commissioner of Ontario. The Mining and Lands Commissioner then ordered that Cliffs provide KWG with the applicant’s case and evidence, so that KWG might have an opportunity to respond. KWG’s management is of the view that the outcome of this process will confirm that the Crown may not effect an expropriation from a minority joint-venturer in order to prefer the exclusive interest of the majority joint-venturer.

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GLTA.

BaBe.