What changed in this filing

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Item 1B. Unresolved Staff Comments

2026-03-31 compared with 2025-03-31 · 69 added, 73 removed, 8 unchanged (95% of the section changed)

Unresolved Staff Comments.

Staff Comments.

Not applicable.

Cybersecurity.

We believe cybersecurity is

critical to advancing our technological developments.

We face a multitude of cybersecurity threats that range from attacks common to most

industries, such as ransomware and denial-of service.

Our customers, suppliers, subcontractors, and business partners face similar cybersecurity

threats, and a cybersecurity incident impacting us or any of these entities could materially adversely affect our business strategy, performance,

and results of operations.

These cybersecurity threats and related risks make it imperative that we expend resources on cybersecurity.

Risk Management

We engage third-party services

to conduct evaluations of our security controls, whether through penetration testing, independent audits, or consulting on best practices

to address new challenges.

We have established cybersecurity security awareness training and ongoing monitoring.

In the event of an incident,

we intend to follow our cybersecurity incident response plan, which outlines the steps to be followed from incident detection to mitigation,

and notification.

We contract with external firms that have extensive information technology and program management experience.

implemented a governance structure and processes to assess, identify, manage, and report cybersecurity risks.

We must comply with extensive

regulations, including requirements imposed by the Federal Drug Administration related to adequately safeguarding patient information

and reporting cybersecurity incidents to the SEC.

We believe we are positioned to meet the requirements of the SEC.

Assessing, identifying,

and managing cybersecurity related risks are factored into our overall business approach.

We rely heavily on our supply chain to deliver

our products and services, and a cybersecurity incident at a clinical site, subcontractor, or business partner could materially adversely

We require that our subcontractors report cybersecurity incidents to us so that we can assess the direct impact of the incident.

The Audit Committee has oversight

responsibility for risks and incidents relating to cybersecurity threats, including compliance with disclosure requirements, cooperation

with law enforcement, and related effects on financial and other risks, and it reports any findings and recommendations, as appropriate,

to the full board of directors for consideration.

Responsible personnel regularly discusses cyber risks and trends and, should they arise,

any material incidents with the Audit Committee.

While we have not experienced

any material cybersecurity threats or incidents in recent years, there can be no guarantee that we will not be the subject of future threats

or incidents.

Notwithstanding the extensive approach we take to cybersecurity, we may not be successful in preventing or mitigating a

cybersecurity incident that could have a material adverse effect on us.

While we maintain cybersecurity insurance, the costs related to

cybersecurity threats or disruptions may not be fully insured.

See “Risk Factors” for a discussion of cybersecurity risks.

Risk Management

We engage third-party services

to conduct evaluations of our security controls, whether through penetration testing, independent audits, or consulting on best practices

to address new challenges.

We have established cybersecurity security awareness training and ongoing monitoring.

In the event of an incident,

we intend to follow our cybersecurity incident response plan, which outlines the steps to be followed from incident detection to mitigation,

and notification.

We contract with external firms that have extensive information technology and program management experience.

implemented a governance structure and processes to assess, identify, manage, and report cybersecurity risks.

We must comply with extensive

regulations, including requirements imposed by the Federal Drug Administration related to adequately safeguarding patient information

and reporting cybersecurity incidents to the SEC.

We believe we are positioned to meet the requirements of the SEC.

In addition to following

SEC guidance and implementing pre-existing third party frameworks, we have developed our own practices and frameworks, which we believe

enhance our ability to identify and manage cybersecurity risks.

Cybersecurity is important

to our operations and technological development efforts.

We face a multitude of cybersecurity threats that range from attacks common

to most industries, such as ransomware and denial-of-service.

Our customers, suppliers, subcontractors, and business partners face similar

cybersecurity threats, and a cybersecurity incident impacting us or any of these entities could materially adversely affect our business

strategy, performance, and results of operations.

These cybersecurity threats and related risks make it imperative that we expend resources

on cybersecurity.

We have processes in

place for assessing, identifying, and managing material risks from potential unauthorized occurrences on or through our information systems

that could adversely affect the confidentiality, integrity, or availability of our information systems or the information residing on

those systems.

These include mechanisms, controls, and processes that are designed to prevent, detect, or mitigate data loss, theft,

misuse, unauthorized access, or other security incidents or vulnerabilities affecting the data.

The data includes confidential, proprietary,

and business and personal information that we collect, process, store, and transmit as part of our business, including on behalf of third

We consider cybersecurity risks associated with third-party vendors and service providers as part of our overall risk management

processes and may assess such vendors’ security practices where appropriate.

We maintain a cybersecurity

risk management program operating under our Information Security & Risk Management Strategy (“ISRM”).

This program is

responsible for implementing and maintaining cybersecurity and data protection practices at Aditxt in close coordination with management

and other teams across Aditxt.

In addition to our in-house cybersecurity capabilities, we may engage assessors, consultants, auditors,

or other third parties to assist with assessing, identifying, and managing cybersecurity risks .

Management evaluates cybersecurity risks

and associated mitigation efforts.

As of the date of this report, the Company is not aware of any material risks from cybersecurity threats

that have materially affected or are reasonably likely to materially affect the Company, including its business strategy, results of

operations, or financial condition.

Despite the measures we take to manage cybersecurity risk, we may not be successful in preventing

or mitigating a cybersecurity incident that could have a material adverse effect on the Company or its stakeholders.

The Audit Committee

oversees the Company’s cybersecurity risk management, including oversight of the Company’s Information Security & Risk

Management Strategy (“ISRM”).

The ISRM establishes a governance framework for cybersecurity oversight and designates an ISRM

Leadership Group responsible for implementing and maintaining the Company’s cybersecurity and data protection practices.

reports to the Audit Committee regarding cybersecurity risks and significant cybersecurity incidents.

We evaluate our security

controls through internal assessments and may engage third-party services to support penetration testing, independent reviews, or consulting

on best practices.

We have established cybersecurity awareness training and ongoing monitoring.

In the event of a cybersecurity

incident, we follow established procedures to respond to and mitigate its impact, including coordination among internal personnel, use

of external service providers where appropriate, and implementation of disaster recovery procedures.

We may engage external firms with

information technology and program management experience to assist in evaluating or managing cybersecurity risks.

We have implemented

a governance structure and processes to assess, identify, manage, and report cybersecurity risks.

We must comply with extensive regulations,

including requirements imposed by the U.S.

Food and Drug Administration, laws governing the protection of patient information, and SEC

requirements related to cybersecurity incident disclosure.

Assessing, identifying, and managing cybersecurity-related risks are factored

2 unchanged sentences

at a clinical site, subcontractor, or business partner could materially adversely impact us.

We require that our subcontractors report

cybersecurity incidents to us so that we can assess the direct impact of the incident.

The Audit Committee has oversight

responsibility for risks and incidents relating to cybersecurity threats, including compliance with disclosure requirements, cooperation

with law enforcement, and related effects on financial and other risks, and it reports any findings and recommendations, as appropriate,

to the full board of directors for consideration.

Senior management regularly discusses cyber risks and trends and, should they arise,

any material incidents with the Audit Committee.

We expect our subcontractors to report cybersecurity

incidents to us so that we can assess the potential impact.

The Audit Committee

has oversight responsibility for risks and incidents relating to cybersecurity threats, including compliance with disclosure requirements,

cooperation with law enforcement, and related effects on financial and other risks, and it reports any findings and recommendations,

as appropriate, to the full board of directors for consideration .

Management provides periodic reports to the Audit Committee regarding

cybersecurity risks and trends and any material cybersecurity incidents.

While we have not experienced

any material cybersecurity threats or incidents in recent years, there can be no guarantee that we will not be the subject of future threats

or incidents.

Notwithstanding the extensive approach we take to cybersecurity, we may not be successful in preventing or mitigating a

cybersecurity incident that could have a material adverse effect on us.

While we maintain cybersecurity insurance, the costs related to

cybersecurity threats or disruptions may not be fully insured.

any material cybersecurity threats or incidents in recent years, there can be no guarantee that we will not be the subject of future

threats or incidents.

Despite the measures we take to manage cybersecurity risk, we may not be successful in preventing or mitigating

a cybersecurity incident that could have a material adverse effect on us.

While we maintain cybersecurity insurance, the costs related

to cybersecurity threats or disruptions may not be fully insured.

See “Risk Factors” for a discussion of cybersecurity risks.

Compared sentence by sentence after normalising whitespace, quotation marks, case and digits, so re-formatting and restated figures do not read as changed language. Wording changes appear as one removal and one addition. The current filing and the prior one are authoritative.

What changed 10-K

Item 1B. Unresolved Staff Comments