4 unchanged sentences
Based on this evaluation, our principal executive officers and principal financial officer concluded that our disclosure controls and procedures were not effective at the reasonable assurance level due to the material weaknesses in our internal control over financial reporting, as further described below:
−Removed: We concluded that certain material weaknesses in our internal control over financial reporting are still present as of June 30, 2021.
+Added: We concluded that certain material weaknesses in our internal control over financial reporting are still present as of September 30, 2021.
The material weaknesses present are as follows:
We did not maintain an effective control environment as we did not maintain a sufficient complement of accounting and financial reporting resources commensurate with our financial reporting requirements.
−Removed: This material weakness contributed to the following material weaknesses:
+Added: This material weakness contributed to the following material weakness:
We did not have sufficient resources to appropriately record revenue transactions, nor did we did have controls in place to validate that the terms of the revenue transactions were appropriately entered into the revenue sub-ledger based on the terms of the arrangement with the customer.
−Removed: We did not design or maintain effective controls over the period end financial reporting process and preparation of financial statements.
−Removed: Specifically, we did not design and implement a sufficient level of formal accounting policies and procedures that define how transactions across the business cycles should be initiated, recorded, processed and reported and appropriately authorized and approved.
These control deficiencies did not result in errors that were material to our annual or interim financial statements.
2 unchanged sentences
We are in the process of implementing measures designed to improve our internal control over financial reporting and remediate the control deficiencies that led to the material weaknesses.
−Removed: As of June 30, 2021, we have completed the following remedial actions:
+Added: As of September 30 , 2021 , we have completed the following remedial actions:
hired additional full-time accounting resources with appropriate levels of accounting knowledge and experience, including but not limited to a Chief Financial Officer in the second half of 2018, and the following resources who all have significant public company experience:
−Removed: a Vice President of Accounting, Vice President of FP&A, Senior
−Removed: Director of Revenue in the first half of 2019 , Director of SEC Reporting with Big Four Accounting experience and a Corporate Controller in the second half of 2020, and a Senior Revenue Man a ger in the first quarter of 2021 ;
+Added: a Vice President of Accounting, Vice President of FP&A, Senior Director of Revenue in the first half of 2019, Director of SEC Reporting with Big Four Accounting experience in the second half of 2020, and a Senior Revenue Manager in the first quarter of 2021 ;
reallocated responsibilities across the accounting organization to ensure that the appropriate level of knowledge and experience is applied based on risk and complexity of transactions and tasks under review;
2 unchanged sentences
increased the number of Board Directors on our Audit Committee to three independent Directors late 2020;
−Removed: engaged a Big Four public accounting firm to assist us in the creation of, and ultimately serve as, in an internal audit function, including the establishment of an internal audit charter and assessment, documentation, design and implementation of control activities related to internal controls in the second quarter of 2021.
+Added: engaged a Big Four public accounting firm to assist us in the creation of, and ultimately serve as, an internal audit function, including the establishment of an internal audit charter and assessment, documentation, design and implementation of control activities related to internal controls in the second quarter of 2021.
We have made significant progress towards remediating the material weaknesses and will continue to review, revise, and improve the effectiveness of our internal controls as appropriate Although we have made significant enhancements to our control procedures, these material weaknesses will not be considered remediated until our controls are operational for a sufficient period of time, tested, and management concludes that these controls are operating effectively.
+Added: Remediation of Previously Identified Material Weakness in Internal Control over Financial Reporting
+Added: We previously identified and disclosed in the financial statements as of and for the period ended December 31, 2020 included in our Annual Report on Form 10-K as well as in our Quarterly Report on Form 10-Q for the interim period ended June 30, 2021, a material weakness in our internal control over financial reporting relating to the following:
+Added: We did not design or maintain effective controls over the period end financial reporting process and preparation of financial statements.
+Added: Specifically, we did not design and implement a sufficient level of formal accounting policies and procedures that define how transactions across the business cycles should be initiated, recorded, processed and reported and appropriately authorized and approved.
+Added: Our management, with the oversight from our audit committee, has completed the following remediation steps to address the previously disclosed material weakness:
+Added: hired additional full-time accounting resources with appropriate levels of accounting knowledge and experience, including a Chief Financial Officer in the second half of 2018, a Vice President of Accounting, Vice President of FP&A, and Director of SEC Reporting in the second half of 2020;
+Added: reallocated responsibilities across the accounting organization to ensure that the appropriate level of knowledge and experience is applied based on risk and complexity of transactions and tasks under review ;
+Added: strengthened our internal policies, processes and reviews over period end financial reporting and preparation of financial statements, including formal documentation thereof;
+Added: engaged a professional accounting services firm in the second quarter of 2021 to help us assess, document, design and implement control activities related to internal control over financial reporting.
+Added: Our management concluded that based on the completion of these actions, and the results of our testing over the design and operating effectiveness of the newly designed and implemented controls, the previously-identified material weakness related to the period end financial reporting process and preparation of financial statements was remediated as of September 30, 2021.
Changes in Internal Control over Financial Reporting
−Removed: The second quarter remediation activity described above is a change in internal control over financial reporting during the quarter ended June 30, 2021, that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
+Added: There have been no changes in our internal control over financial reporting during the quarter ended September 30, 2021, that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
Limitations on Effectiveness of Controls and Procedures
10 unchanged sentences
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.