What changed in this filing

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Item 4. Controls and Procedures

2020-11-04 compared with 2020-08-05 · 18 added, 18 removed, 24 unchanged (60% of the section changed)

3 unchanged sentences

effectiveness of the design and operation of our disclosure controls and procedures, as defined in Rules 13a-15(e) and 15d-15(e)

under the Exchange Act, as of June 30, 2020 to ensure that information required to be disclosed by us in the reports filed or

submitted by us under the Exchange Act is recorded, processed, summarized and reported, within the time periods specified in the

Securities and Exchange Commission’s rules and forms, including to ensure that information required to be disclosed

under the Exchange Act, as of September 30, 2020 to ensure that information required to be disclosed by us in the reports filed

or submitted by us under the Exchange Act is recorded, processed, summarized and reported, within the time periods specified in

the Securities and Exchange Commission’s rules and forms, including to ensure that information required to be disclosed

by us in the reports filed or submitted by us under the Exchange Act is accumulated and communicated to our management, including

1 unchanged sentence

decisions regarding required disclosure.

Based on that evaluation, our Chief Executive Officer concluded that as of June 30, 2020,

our disclosure controls and procedures were not effective at the reasonable assurance level due to the following material weaknesses

in our internal control over financial reporting:

Based on that evaluation, our Chief Executive Officer concluded that as of September

30, 2020, our disclosure controls and procedures were not effective at the reasonable assurance level due to the following material

weaknesses in our internal control over financial reporting:

to our small number of employees and limited resources, we have limited segregation of duties, as a result of which there

4 unchanged sentences

applying complex accounting principles.

On September 17, 2018,

the Board of Directors of the Company concluded that due to ineffective controls we failed to follow GAAP in accounting for our

digital assets.

This failure arose from a material weakness which required us to restate our financial statements for the nine

months ended September 30, 2018 as well as two other periods.

Further, in April 2020, the Company received an oral comment from

the Staff of the SEC regarding the classification of Digital Asset transactions as an Investing Activity in its Cash Flow Statement

within the Company’s Form 10-K for the year ended December 31, 2019 (“Form 10-K).

Prior to the filing of the Form

10-K, in response to a prior SEC comment, the Company agreed to include Digital Assets transactions in its future filings as an

Operating Activity but failed to do so in the Form 10-K.

The Company filed a 10-K/A which addressed this future filing request.

September 17, 2018, the Board of Directors of the Company concluded that due to ineffective controls we failed to follow GAAP

in accounting for our digital assets.

This failure arose from a material weakness which required us to restate our financial statements

for the nine months ended September 30, 2018 as well as two other periods.

Further, in April 2020, the Company received an oral

comment from the Staff of the SEC regarding the classification of Digital Asset transactions as an Investing Activity in its Cash

Flow Statement within the Company’s Form 10-K for the year ended December 31, 2019 (“Form 10-K).

Prior to the filing

of the Form 10-K, in response to a prior SEC comment, the Company agreed to include Digital Assets transactions in its future

filings as an Operating Activity but failed to do so in the Form 10-K.

The Company filed a 10-K/A which addressed this future

filing request.

in Internal Control over Financial Reporting

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.

What changed 10-Q

Item 4. Controls and Procedures