What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-03-31 compared with 2024-03-06 · 45 added, 15 removed, 2 unchanged (97% of the section changed)

Unresolved Staff Comments

Not applicable.

Cybersecurity

We are a special purpose acquisition

company with no business operations.

Since our IPO, our sole business activity has been identifying and evaluating suitable acquisition

transaction candidates.

Therefore, we do not consider that we face significant cybersecurity risk.

We have not adopted any cybersecurity

risk management program or formal processes for assessing cybersecurity risk.

Our management is generally responsible for assessing and

managing any cybersecurity threats.

If and when any reportable cybersecurity incident arises, our management shall promptly report such

matters to our board of directors for further actions, including regarding the appropriate disclosure, mitigation, or other response or

actions that the board deems appropriate to take.

As of the date of this report, we have not encountered any cybersecurity

incidents since our IPO.

Risk Management and Strategy

We have an information security

program designed to identify, protect, detect and respond to, and manage reasonably foreseeable cybersecurity risks and threats.

our information systems from cybersecurity threats, we utilize various security tools that help prevent, identify , escalate, investigate,

resolve, and recover from identified vulnerabilities and security incidents in a reasonably timely manner.

These include, but are not

limited to, internal reporting and tools for monitoring and detecting cybersecurity threats.

We evaluate the risks associated

with technology and cybersecurity threats and monitor our information systems for potential weaknesses.

We review and test our information

technology system on an as-needed basis and also utilize internal team personnel to evaluate and assess the efficacy of our information

technology system and enhance our controls and procedures.

The results of these assessments are reported to our [Audit Committee] and,

from time to time, our Board of Directors.

There can be no assurances

that our cybersecurity risk management program and processes, including our policies, controls, or procedures, will be fully implemented,

complied with or are effective in protecting our systems and information.

As of the date of this report,

we are not aware of any cybersecurity incidents, that have had a materially adverse effect on our operations, business, results of operations,

or financial condition.

Our Board of Directors considers

cybersecurity risk as part of its risk oversight function.

It has delegated oversight of cybersecurity and other information technology

risks to the Audit Committee of the Board of Directors.

The Audit Committee oversees the implementation of the cybersecurity risk management

The Audit Committee receives

periodic reports from management on potential cybersecurity risks and threats.

The Audit Committee reports to the full Board of Directors

regarding its activities, including those related to cybersecurity.

The full Board of Directors also receives briefings from management

on the cybersecurity risk management program as needed.

Management is responsible

for assessing and managing our material risks from cybersecurity threats.

Management has primary responsibility for our overall cybersecurity

risk management program and supervises both the internal cybersecurity personnel and external cybersecurity consultants.

The management team supervises

efforts to prevent, detect, mitigate, and remediate cybersecurity risks and incidents through various means, which may include briefings

from internal security personnel, threat intelligence and other information obtained from governmental, public or private sources, including

external consultants;

and alerts and reports produced by security tools deployed in the IT environment.

Our cybersecurity incident response

plan governs our assessment and response upon the occurrence of a material cybersecurity incident, including the process for informing

senior management and our Board of Directors.

Our executive office Unit 5, 21/F., Westley Square,

48 Hoi Yuen Road, Kwun Tong, Kowloon, Hong Kong.

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