Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS.
Not applicable.
ITEM 1C. CYBERSECURITY.
We
face cybersecurity risks as a result of the variety of networks and systems we must defend against cybersecurity attacks; and the level
of harm that could occur if we suffer impacts of a material cybersecurity incident. We are committed to robust oversight of these risks
and implementing mechanisms, controls, technologies, and processes designed to help us assess, identify, and manage these risks. In the
year ended December 31, 2023, we did not experience a material “cybersecurity incident” as such term is defined in Item
106(a) of Regulation S-K. However, we have experienced two such material breaches in the past (see Form 10-K for the year ended 2023)
and there can be no guarantee that we will not experience such incidents in the future. Such incidents could result in us incurring significant
costs related to implementing threat protection measures, and the possibility of such incidents could result in additional costs in defending
against litigation, responding to regulatory inquiries or actions, paying damages, or taking other remedial steps with respect to third
parties, as well as incurring significant reputational harm. Further, cybersecurity threats are constantly evolving, increasing the difficulty
of successfully defending against them or implementing adequate preventative measures. While we seek to detect and investigate unauthorized
attempts and attacks against our network and to prevent their occurrence where practicable, we remain potentially vulnerable to known
or unknown threats. In some instances, we may be unaware of a threat or incident or its magnitude and effects for some time. Further,
there is increasing regulation regarding responses to cybersecurity incidents, including reporting to regulators, which could subject
us to additional liability and reputational harm. See “Item 1A. Risk Factors” of this Annual Report for more information
on our cybersecurity risks and product vulnerability risks.
We incorporate
industry best practices throughout our cybersecurity program to the extent practicable for a company of our size and resources. New leadership
is committed to improving our cybersecurity strategy, with the goal of enhancing controls, technologies, and other processes to assess,
identify, and manage material cybersecurity risks. Our cybersecurity program will be aligned with applicable industry standards and maintained
by a third-party technology firm. The third-party firm has processes in place to assess, identify, manage, and address material cybersecurity
threats and incidents. These include, among other things, annual and ongoing security awareness advice for employees; mechanisms to detect
and monitor unusual network activity; and containment and incident response tools.
Our third-party
IT/ cybersecurity firm reports to our Chief Executive Officer (“CEO”). The third-party firm is informed about and monitors
prevention, detection, mitigation, and remediation efforts through regular communication and reporting from professionals within its team
and through the use of technological tools and software. Our CEO reports directly to the Board of Directors on our cybersecurity program
and efforts to prevent, detect, mitigate, and remediate issues. Cybersecurity reviews by the Board of Directors will occur at least annually,
or more frequently as determined to be necessary or advisable.
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.