What changed in this filing

/stocks — the workspaceLOADING

Item 1B. Unresolved Staff Comments

2026-03-30 compared with 2025-06-30 · 104 added, 35 removed, 2 unchanged (99% of the section changed)

1 unchanged sentence

CYBERSECURITY

acknowledge the increasing importance of cybersecurity in today’s digital and interconnected world.

Cybersecurity threats pose

significant risks to the integrity of our systems and data, potentially impacting our business operations, financial condition and reputation.

a smaller reporting company, we currently do not have enhanced cybersecurity measures, a dedicated cybersecurity team or robust protocols

in place to manage cybersecurity risks.

We have not yet conducted comprehensive risk assessments, established an incident response plan

or engaged with external cybersecurity consultants for assessments or services.

We intend to invest more resources into improving our

assessment and response to cybersecurity risk in the future.

our current stage of cybersecurity development, we have not experienced any significant cybersecurity incidents to date.

recognize that the absence of a formalized cybersecurity framework may leave us vulnerable to cyberattacks, data breaches and other cybersecurity

Such events could potentially lead to unauthorized access to, or disclosure of, sensitive information, disrupt our business

operations, result in regulatory fines or litigation costs and negatively impact our reputation among customers and partners.

cybersecurity incidents could have material adverse effects on our business strategy, financial condition, and results of operations

(e.g., a significant breach could result in direct financial losses due to fraud, system downtime impacting revenue generation, increased

compliance costs or contractual liabilities with third-party vendors and customers).

are in the process of evaluating our cybersecurity needs and developing appropriate measures to enhance our cybersecurity posture.

includes considering the engagement of external cybersecurity experts to advise on best practices, conducting vulnerability assessments

and developing an incident response strategy.

Our goal is to establish a cybersecurity framework that is commensurate with our size,

complexity and the nature of our operations, thereby reducing our exposure to cybersecurity risks.

addition, the Board will oversee any cybersecurity risk management framework, and the Board’s governance committee will review

and approve any cybersecurity policies, strategies and risk management practices.

Board (or designated committee or officer) will receive periodic updates on cybersecurity risks, including emerging threats, mitigation

efforts and incident response activities.

The updates will be provided at least annually, or more frequently as needed, to ensure cybersecurity

risks are appropriately managed and integrated into our broader risk oversight strategy.

our efforts to improve our cybersecurity measures, there can be no assurance that our initiatives will fully mitigate the risks posed

by cyber threats.

The landscape of cybersecurity risks is constantly evolving, and we will continue to assess and update our cybersecurity

measures in response to emerging threats.

We may consider cybersecurity insurance coverage in the future, which will cover damages from

a range of potential cyber security issues including but not limited to property damage, privacy liability, privacy regulatory defense,

cyber extortion and post breach remediation.

a discussion of potential cybersecurity risks affecting us, please refer to the “ Risk Factors ” section.

Company recognizes the increasing complexity and significance of cybersecurity risks in safeguarding its technology, operations, proprietary

systems, and data.

The Company’s operations rely on interconnected digital infrastructure, cloud-based systems, and proprietary software

platforms, including systems supporting digital asset management and cryptocurrency operations, making cybersecurity an essential component

of its risk management framework.

Company has implemented a cybersecurity program designed to identify, assess, mitigate, and respond to cybersecurity risks.

is informed by recognized industry practices, including the National Institute of Standards and Technology (“NIST”) Cybersecurity

Framework (“CSF”).

The following disclosure outlines the Company’s cybersecurity risk management strategy and governance, including

the Board’s oversight and management’s role.

Cybersecurity Risk Management

Company employs a structured cybersecurity risk management program to assess, identify, and manage cybersecurity risks across its information

technology environment, including corporate systems and cloud-based platforms.

The Company currently operates in part through shared

IT infrastructure and personnel, which provides continuity of cybersecurity controls and practices while the Company develops its standalone

capabilities.

Key elements of the program include:

assessments and periodic evaluation of cybersecurity risks across systems and environments.

detection and monitoring, including alert triage and investigation, to identify suspicious

activity and potential incidents.

● Vulnerability

management, including scanning, prioritization, and remediation activities.

controls and security protections, including multi-factor authentication, encryption protocols,

and endpoint security measures where appropriate.

● Third-party

risk management, including evaluation of vendors and service providers that may access Company

data or systems.

● Cybersecurity

risks are evaluated in coordination with management and are considered within the Company’s

broader operational and enterprise risk considerations.

Governance and Oversight

Cybersecurity

oversight is a shared responsibility between the Company’s Board of Directors and management.

The Vice President provides cybersecurity

updates to the full Board as appropriate, including information regarding the Company’s cybersecurity posture, risk environment, incident

trends, and mitigation efforts.

The Company is in the process of establishing a formal cadence of cybersecurity reporting to the Board

as part of its ongoing business transition.

In addition to scheduled updates, management’s incident response procedures require that

potential material cybersecurity incidents are escalated to senior leadership and the Board promptly, as appropriate.

The Company enforces

a top-down approach to cybersecurity governance, ensuring accountability and continuous risk monitoring at all levels of the organization.

Management’s Role in Cybersecurity

is responsible for the day-to-day execution of the Company’s cybersecurity program.

The Vice President oversees cybersecurity initiatives

and supervises cybersecurity personnel and processes.

The Company’s cybersecurity incident response governance is supported by an Incident

Response Policy that is in the process of being established and will define roles and responsibilities, incident classification, documentation

expectations, evidence preservation requirements, and communication protocols.

Cybersecurity Strategy and Resilience

Company maintains cybersecurity resilience measures designed to support business continuity and protect critical assets.

These measures

include monitoring and response capabilities, as well as processes for containment, remediation, and recovery when incidents occur.

Material Cybersecurity Incidents

fiscal year 2025, the Company did not experience any material cybersecurity incidents.

No cybersecurity incidents required disclosure

under Form 8-K Item 1.05 during 2025.

Impact of Cyber Incidents

Cybersecurity

incidents, if material, could adversely affect the Company’s financial condition, results of operations, operational stability, and reputation.

Potential impacts may include remediation costs, operational disruptions, litigation or regulatory exposure, and reputational harm.

Company evaluates cybersecurity risks as part of its ongoing risk assessment processes.

Board Expertise in Cybersecurity

Board’s cybersecurity oversight is informed through management briefings and periodic updates.

The Company may enhance Board education

on cybersecurity trends and governance practices as appropriate.

Use of Third-Party Services

Company uses third-party service providers to support certain technology and security functions.

Digital asset custody services are provided

by BitGo, a qualified custodian maintaining its own security controls and compliance frameworks.

The Company evaluates third-party cybersecurity

risks through vendor due diligence processes, including review of security documentation and reports where applicable, and monitors third-party

risks on an ongoing basis.

Given the nature of the Company’s cryptocurrency-focused operations, the security practices of digital asset

custodians and blockchain infrastructure providers are a particular focus of the Company’s third-party risk management process.

Regulatory and Legal Compliance Risks

Company is subject to cybersecurity and data privacy requirements, including applicable data privacy laws and SEC disclosure requirements.

Failure to comply with applicable requirements could result in financial penalties, legal liabilities, and reputational harm.

performs compliance-focused activities as part of its cybersecurity program.

Incident Response Plan

Company maintains an incident response policy framework intended to support timely identification, containment, investigation, remediation,

and recovery.

Incident response procedures include incident severity classification, escalation, documentation, evidence preservation,

and communications protocols.

Cyber Insurance

Company does not maintain standalone cybersecurity insurance coverage.

The Company evaluates risk mitigation and risk transfer options

as part of its broader risk management considerations.

Historical Cyber Incidents

Company did not record any material cybersecurity incidents during fiscal year 2025.

Technology and Infrastructure Risks

Company’s cybersecurity program includes measures intended to protect systems and data, including monitoring, endpoint protections, access

controls, and vulnerability management.

As cybersecurity threats continue to evolve, the Company may adjust its cybersecurity tools,

processes, and controls over time.

Data Security and Privacy Policies

Company maintains policies and controls intended to protect sensitive data, including access controls and other security measures designed

to safeguard data confidentiality and integrity.

Ongoing Cybersecurity Efforts

Company continues to invest in cybersecurity capabilities, including monitoring, vulnerability management, employee awareness training,

and improvements to policies and procedures, to address evolving cybersecurity threats.

As a company in transition, the Company expects

to continue developing its standalone cybersecurity infrastructure and formalizing its governance processes accordingly.

The Company is currently essentially “virtual.”

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