What changed in this filing

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Item 1B. Unresolved Staff Comments

2026-03-12 compared with 2025-04-02 · 71 added, 49 removed, 31 unchanged (79% of the section changed)

6 unchanged sentences

While we are in the process of enhancing our cybersecurity practices, we

are committed to continually improving and adapting to evolving threats to maintain a high standard of protection.

are committed to continually improving and adapting to evolving threats to maintain a high standard of protection and to meet industry

best practices.

Managing Material Risks and Integrated Overall

3 unchanged sentences

critical systems.

We use information security management standards like ISO 27001 as a guide to help us identify, assess, and manage cybersecurity

risks relevant to our business.

We are actively integrating

cybersecurity risk management into our broader enterprise risk management framework.

This integration is designed to promote a company-wide

culture of cybersecurity awareness and risk management.

Our risk management team, in collaboration with external consultants, is assessing

and addressing cybersecurity risks in alignment with our operational and business needs.

This ongoing integration ensures that cybersecurity

considerations are increasingly embedded in our decision-making processes at every level.

We use information security management standards, such as ISO 27001, as a guide to help us identify, assess, and manage

cybersecurity risks relevant to our business.

We have integrated cybersecurity

risk management into our broader enterprise risk management framework.

This integration is designed to promote a company-wide culture

of cybersecurity awareness and risk management.

Our risk management team, in collaboration with external consultants, has assessed and

addressed and continues to assess and address cybersecurity risks in alignment with our operational and business needs.

This integration

ensures that cybersecurity considerations are increasingly embedded in our decision-making processes at every level.

Our cybersecurity framework

draws upon the National Institute of Standards and Technology (“NIST”) cybersecurity framework, which provides guidance for

identifying, assessing, and managing cybersecurity risks.

While we are in the early stages of fully implementing this framework, we are

committed to following its principles as we strengthen our cybersecurity measures to protect both our digital and physical assets.

also draws upon the National Institute of Standards and Technology Cybersecurity Framework (at its currently 2.0 version), which provides

guidance for identifying, assessing, and managing cybersecurity risks.

While we are in the early stages of fully implementing this framework,

we are committed to following its principles as we strengthen our cybersecurity measures to protect both our digital and physical assets.

Engage Third-parties on Risk Management

Recognizing the evolving nature

of cybersecurity threats, we have been engaging with external experts, including cybersecurity assessors, consultants, and auditors, to

assess and enhance our risk management systems.

These third parties are assisting us with evaluating our cybersecurity posture, recommending

improvements, and advising on the implementation of best practices.

As we progress, we will continue leveraging these external insights

to enhance our cybersecurity strategies and ensure alignment with industry standards.

of cybersecurity threats, we have engaged with external experts, including cybersecurity assessors, consultants, and auditors, to assess

and enhance our risk management systems.

These third-parties have and continue to assist us with evaluating our cybersecurity posture,

recommending improvements, and advising on the implementation of best practices.

In 2025, we completed a comprehensive cybersecurity assessment

across all platforms with external experts, such as Amazon Web Services, amongst others.

As we progress, we will continue leveraging these

external insights to enhance our cybersecurity strategies and ensure alignment with industry standards.

Oversee Third-party Risk

7 unchanged sentences

To date, we have not encountered

cybersecurity incidents that have materially impaired our operations or financial position.

However, we are proactively preparing for

the possibility of cybersecurity risks, ensuring that our systems are protected against potential threats in the future.

Our board of directors understands

the critical nature of cybersecurity and is closely involved in overseeing our efforts to mitigate cybersecurity risks.

We are in the

process of formalizing governance structures and oversight mechanisms to ensure that these risks are managed effectively, with the aim

of strengthening our operational integrity and enhancing stockholder confidence.

cybersecurity incidents that have materially impaired our operations or financial condition.

However, given the data-driven nature of

our business and the prevalent use of technology in operating our business, we face cybersecurity risks inherent to our normal course

of operation that, if realized, are reasonably likely to materially affect our operations or financial condition.

As a result, we have

a dedicated cybersecurity response team and proactively prepare for the possibility of cybersecurity risks, ensuring that our systems

are protected against potential threats.

The cybersecurity response team (i) responds to actual and suspected cybersecurity threats, (ii)

assesses the severity of any such actual or suspected cybersecurity threat, (iii) prepares and maintains incident reports and (iv) prepares

cybersecurity incident response procedures designed to help protect the security of the Company’s systems.

Our Board understands the

critical nature of cybersecurity and is closely involved in overseeing our efforts to mitigate cybersecurity risks.

We continue to formalize

governance structures and oversight mechanisms to ensure that these risks are managed effectively, with the aim of strengthening our operational

integrity and enhancing stockholder confidence.

As of December 31, 2025, no risks from cybersecurity threats, including as a result of

cybersecurity incidents we have experienced in the past, have materially affected us, including our results of operations and financial

Management’s Role Managing Risk

The Chief Executive Officer

(“CEO”), Chief Operating Officer (“COO”), and Chief Financial Officer (“CFO”) are actively involved

in managing cybersecurity risks.

They receive regular updates, which include an overview of the current cybersecurity landscape, the status

of ongoing initiatives, and compliance with regulatory requirements.

We are establishing structured processes for ongoing communication

among the executive team to ensure they remain informed and involved in key cybersecurity decisions.

Our Chief Technology Officer

(“CTO”) is the senior officer responsible for cybersecurity risk management.

Our CTO receives regular updates, which include

an overview of the current cybersecurity landscape, the status of ongoing initiatives, and compliance with regulatory requirements.

are establishing structured processes for ongoing communication among the executive team to ensure they remain informed and timely involved

in key cybersecurity decisions.

Risk Management Monitoring

We are committed to monitoring

cybersecurity risks and are in the process of implementing enhanced monitoring systems.

With the assistance of cybersecurity consultants,

we are refining our cybersecurity policies and controls, including regular audits and the deployment of advanced security measures such

as Multi-Factor Authentication (“MFA”) and stronger email filtering protocols.

In addition, we are continuing to develop incident

response plans, communication protocols, and disaster recovery plans to be prepared for any potential cybersecurity incidents.

We are committed to regularly

monitoring cybersecurity risks and are in the process of implementing enhanced monitoring systems.

With the assistance of cybersecurity

consultants, we are refining our cybersecurity policies and controls, including regular audits and the deployment of advanced security

measures such as Multi-Factor Authentication and stronger email filtering protocols.

In addition, we have an incident response team and

are continuing to refine our incident response plans, communication protocols, and disaster recovery plans to be prepared for any potential

cybersecurity incidents.

Security Training

3 unchanged sentences

ensure that our employees are well-prepared to identify and respond to cybersecurity threats in an effective manner.

Reporting to Board of Directors

The COO regularly informs

the CEO and CFO on cybersecurity risks and initiatives.

Significant cybersecurity matters will be escalated to the audit committee for

review, where management will provide detailed updates on risk assessments, incident response, and the effectiveness of our cybersecurity

The audit committee will continue to evaluate the progress of our cybersecurity initiatives and offer guidance to help strengthen

Reporting to Management and the Board

The CTO regularly provides

reports and informs the CEO and CFO cybersecurity profile.

These reports address the status of risk mitigation initiatives, the evolving

threat landscape, the results of vulnerability assessments and penetration testing, and the progress of key cybersecurity programs, including

the implementation of a Zero Trust access framework, continuous vulnerability scanning with centralized alerting, and our pursuit of SOC

The Board maintains direct

oversight of the Company’s cybersecurity program.

Management provides the Board with no fewer than annual comprehensive briefings

on cybersecurity risk assessment, the effectiveness of the Company’s information security controls and the status of ongoing cybersecurity

These briefings also cover the Company’s incident response preparedness and any changes in the regulatory environment

affecting the Company’s cybersecurity obligations.

In addition to the regularly

scheduled briefings, significant cybersecurity matters will be escalated to the Board for review, where management, including the CTO,

will provide detailed updates on risk assessments, incident responses, and the effectiveness of our cybersecurity strategies.

will continue to evaluate the progress of our cybersecurity initiatives and offer guidance to help strengthen our efforts.

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