What changed in this filing

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Item 4. Controls and Procedures

2020-11-09 compared with 2020-08-07 · 29 added, 26 removed, 2 unchanged (96% of the section changed)

CONTROLS AND PROCEDURES

of Disclosure Controls and Procedures

controls and procedures are designed to ensure that information required to be disclosed by us in reports filed or submitted under

the Securities Exchange Act of 1934, as amended (“Exchange Act”) is recorded, processed, summarized and reported within

the time periods specified in the SEC’s rules and forms.

Evaluation of Disclosure Controls

and Procedures

Disclosure controls and procedures are

designed to ensure that information required to be disclosed by us in reports filed or submitted under the Securities Exchange

Act of 1934, as amended (“Exchange Act”) is recorded, processed, summarized and reported within the time periods specified

in the SEC’s rules and forms.

Disclosure controls and procedures include, without limitation, controls and procedures designed

to ensure that information required to be disclosed under the Exchange Act is accumulated and communicated to management, including

the principal executive and financial officers, as appropriate to allow timely decisions regarding required disclosure.

inherent limitations to the effectiveness of any system of disclosure controls and procedures, including the possibility of human

error and the circumvention or overriding of the controls and procedures.

Accordingly, even effective disclosure controls and procedures

can only provide reasonable assurance of achieving their control objectives.

In connection with the preparation of the

quarterly report on Form 10-Q for the quarter ended September 30, 2020, our management, including our principal executive officer

and principal financial officer, carried out an evaluation of the effectiveness of our disclosure controls and procedures, which

are defined in Rules 13a-15(e) and 15d-15(e) of the Exchange Act.

Disclosure controls and procedures include, without limitation,

controls and procedures designed to ensure that information required to be disclosed under the Exchange Act is accumulated and

communicated to management, including the principal executive and financial officers, as appropriate to allow timely decisions

regarding required disclosure.

There are inherent limitations to the effectiveness of any system of disclosure controls and procedures,

including the possibility of human error and the circumvention or overriding of the controls and procedures.

Accordingly, even

effective disclosure controls and procedures can only provide reasonable assurance of achieving their control objectives.

connection with the preparation of the quarterly report on Form 10-Q for the quarter ended June 30, 2020, our management, including

our principal executive officer and principal financial officer, carried out an evaluation of the effectiveness of our disclosure

controls and procedures, which are defined in Rules 13a-15(e) and 15d-15(e) of the Exchange Act.

Disclosure controls and procedures

include, without limitation, controls and procedures designed to ensure that information required to be disclosed by an issuer

in the reports that it files or submits under the Exchange Act is accumulated and communicated to the issuer’s management,

including its principal executive and principal financial officers, or persons performing similar functions, as appropriate to

allow timely decisions regarding required disclosure.

on this evaluation, management concluded that our internal control over financial reporting were not effective as of June 30,

2020 due to the significant deficiencies which aggregate to a material weakness and was previously reported in our Form 10-K Annual

Report for the year ended December 31, 2019 (“2019 10-K”), that have not yet been remediated.

in Internal Controls Over Financial Reporting

were no changes in our internal controls over financial reporting that occurred during the period covered by this report that

has materially affected, or is reasonably likely to materially affect, our internal control over financial reporting.

II - OTHER INFORMATION

controls and procedures designed to ensure that information required to be disclosed by an issuer in the reports that it files

or submits under the Exchange Act is accumulated and communicated to the issuer’s management, including its principal executive

and principal financial officers, or persons performing similar functions, as appropriate to allow timely decisions regarding required

Based on this evaluation, management concluded

that our internal control over financial reporting were not effective as of September 30, 2020 due to the significant deficiencies

which aggregate to a material weakness and was previously reported in our Form 10-K Annual Report for the year ended December 31,

2019 (“2019 10-K”), that have not yet been remediated.

Internal Controls Over Financial Reporting

There were no changes in our internal controls

over financial reporting that occurred during the period covered by this report that has materially affected, or is reasonably

likely to materially affect, our internal control over financial reporting.

PART II - OTHER INFORMATION

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