In the last two weeks, there have been more than a few articles and law firm memos written on the SEC’s FAQs relating to the Conflict Minerals Rule. Many of the articles and memos recite the FAQs. Others provide a brief discussion of them. Most are calling the FAQs the only guidance from the SEC since the Release last August. But, a careful read of the SEC’s Reply Brief filed in the legal challenge gives additional insight into how the SEC might interpret certain elements of the Conflict Minerals Rule.