According to Exogal CEO Jeff Haagenstad in conversation with Michael Lavorgna of Audiostream:
"The longer version is that we don't do our D to A conversion in a conventional way. We have implemented a 6-core DSP in an FPGA (and we blew the "Read" bit, so we can write to it for upgrades but it can't be read or decompiled...) and we use some signal processing approaches that are unconventional in audio but not in wider signal processing work."
"The EXOGAL DSP platform (on which the Comet is the first of many products to exploit the technology) does have some conventional DAC chips but only the final output stages of the DAC chips are used for the final translation into analog. The main output uses PCM4104 DAC's and the headphones use PCM5122 DAC's. The outputs are buffered using TI/National LME49600 buffers. These are high-current, high-impedance, class AB buffers with no feedback. Beyond that, we ain't sayin' "
Read more at https://www.audiostream.com/content/exogal-comet-dac#zHAKuQUy8iV0yglU.99