Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments
Not applicable.
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Item 1C. Cybersecurity
Risk Management and Strategy
Managing Material Risks & Integrated Overall
Risk Management
In the normal course of business, we may collect and
store certain sensitive company information, including proprietary and confidential business information. We maintain various protections
designed to safeguard against cyberattacks, including firewalls, key-based authentication, and virtual private networks. We protect against
business interruption by backing up our major systems. We consider these cybersecurity risk management efforts as part of our broader
risk management framework. This integration helps ensure that cybersecurity considerations are a fundamental part of our decision-making
processes. Our management team works with our audit committee and board of directors (the “Board”) to evaluate and address
cybersecurity risks in alignment with our business objectives and operational needs.
Engage Third Parties on Risk Management
To date, we have not engaged independent third parties
to assess the risks associated with our information technology resources and information assets. In the future, we may engage third parties
to analyze data on the interactions of users of our information technology resources, including our employees, and evaluate the performance
of our cybersecurity systems and processes.
Oversee Third Party Risk
We utilize various third-party software applications
in the functioning of our core business. We consider the cybersecurity practices of our third-party service providers, including through
a general security assessment and contractual requirements, as appropriate, before engaging them in order to help protect us from any
related vulnerabilities. Our assessment of risks associated with the use of third-party providers is part of our overall risk management
framework.
Risks from Cybersecurity Threats
We face risk from cybersecurity threats that could
have a material adverse effect on our business, financial condition, results of operations, cash flows or reputation.
To date, we have not experienced any previous cybersecurity
incidents that have materially affected or are reasonably likely to materially affect our business strategy, results of operations, or
financial condition.
Governance
Board of Directors Oversight
Our Board is aware of the critical nature of managing
risks associated with cybersecurity threats, and recognizes the significance of these threats to our operational integrity and stockholder
confidence.
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Risk Management Personnel
The audit committee is central to the Board’s
oversight of cybersecurity risks and bears the primary responsibility for this domain as part of its broader responsibility for risk assessment
and management. The audit committee is responsible for escalating significant cybersecurity matters and strategic risk management decisions
to the Board, granting the Board comprehensive oversight and the ability to provide guidance on critical cybersecurity issues. We intend
for the audit committee to review the Company’s cybersecurity posture and the effectiveness of its risk management strategies annually
and brief the full Board with respect to the Company’s cybersecurity posture and potential risks on a regular basis, with a minimum
frequency of once per year.
Management’s Role Managing Risk and Reporting
to the Board
We do not currently have an employee who has significant
and demonstrated professional IT management experience and possesses the requisite education, skills and experience needed to develop
and execute our cybersecurity strategies. Presently, our senior management is responsible for monitoring our cybersecurity risks and maintaining
an ongoing dialogue with the audit committee regarding emerging or potential cybersecurity risks as needed. The relationship between senior
management and the audit committee regarding current and emerging cybersecurity concerns helps to integrate cybersecurity consideration
into the Company’s broader strategic objectives.
Item 2. Properties
Our principal executive offices are located at 100 Matawan Rd, Suite 325,
Matawan, New Jersey 07747. Our Digital Asset Treasury business operations are headquartered at 60 Paya Lebar Road #04-23, Singapore 409051.
We do not own any real property. We believe our current facilities are
suitable for our current operations.