Unresolved Staff Comments
−Removed: Cybersecurity
+Added: Not applicable.
Cybersecurity
−Removed: Risk Management and Strategy
−Removed: have established certain processes for assessing, identifying, and managing material risk from cybersecurity threats, and have integrated
−Removed: these processes into our overall risk management strategy.
−Removed: Such processes include physical, procedural and technical safeguards, response
−Removed: methods, regular tests on our systems, and routine review of our processes to identify risks and enhance our practices.
−Removed: We also use technology-based
−Removed: tools to mitigate cybersecurity risks and to bolster our employee-based cybersecurity programs.
+Added: Cybersecurity Risk Management and Strategy
+Added: We have established certain
+Added: processes for assessing, identifying, and managing material risk from cybersecurity threats, and have integrated these processes into
+Added: our overall risk management strategy.
+Added: Such processes include physical, procedural and technical safeguards, response methods, regular
+Added: tests on our systems, and routine review of our processes to identify risks and enhance our practices.
+Added: We also use technology-based tools
+Added: to mitigate cybersecurity risks and to bolster our employee-based cybersecurity programs.
We engage certain external parties, including
consultants and computer security firms to enhance our cybersecurity oversight and provide monthly trainings to our employees.
−Removed: the internal risk oversight programs of third-party service providers before engaging them in order to help protect our company from
−Removed: any related vulnerabilities.
+Added: the internal risk oversight programs of third-party service providers before engaging them in order to help protect our company from any
+Added: related vulnerabilities.
At this time, we are not aware of any material cybersecurity incidents
that have impacted the Company.
−Removed: For a description of the risks from cybersecurity threats that may materially affect us and how they
−Removed: may do so, see our risk factors under Part 1.
+Added: For a description of the risks from cybersecurity threats that may materially affect us and how they may
+Added: do so, see our risk factors under Part 1.
Risk Factors in this Annual Report.
−Removed: board of directors is involved in the oversight of our risk management activities, and cybersecurity represents an important element
−Removed: of our overall approach to risk management.
−Removed: Our board of directors has delegated authority to the Audit Committee to serve as the cybersecurity
−Removed: oversight body, which works with the chief financial officer to assess and respond to cybersecurity threats.
−Removed: The chief financial officer
−Removed: meets with the third-party vendors regularly to discuss any issues and updates related to the Company’s information technology
−Removed: environment and reports to the Audit Committee on a quarterly basis.
−Removed: principal corporate office is located at 4851 Tamiami Trail N, Suite 200 Naples, FL 34103.
−Removed: The Company believes our office is in good
−Removed: condition and is sufficient to conduct our operations.
+Added: Our board of directors is
+Added: involved in the oversight of our risk management activities, and cybersecurity represents an important element of our overall approach
+Added: to risk management.
+Added: Our board of directors has delegated authority to the audit committee to serve as the cybersecurity oversight body,
+Added: which works with the chief financial officer to assess and respond to cybersecurity threats.
+Added: The chief financial officer meets with the
+Added: third-party vendors regularly to discuss any issues and updates related to the Company’s information technology environment and
+Added: reports to the audit committee on a quarterly basis.
+Added: Our principal corporate office
+Added: is located at 245 First Street, Riverview II, 18th Floor, Cambridge, MA 02142.
+Added: The Company believes our office is in good condition and
+Added: is sufficient to conduct our operations.
Our principal corporate office is held under a month-to-month operating lease.
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.