Item 1B. Unresolved Staff Comments
ITEM
1B.
UNRESOLVED
STAFF COMMENTS
None.
ITEM
2.
OPERATING
LEASES
Effective
October 29, 2019, the Company leased office space at 200 Spectrum Center Drive, Suite 300, Irvine, CA 92618. As per the Commitment Term
of the lease (“Agreement”), this Agreement shall continue on a month-to-month basis (any term after the Commitment Term,
also known as “Renewal Term”). The Commitment Term and all subsequent Renewal Terms shall constitute the “Term.”
The Company may terminate this Agreement by delivering to the lessor Form (“Exit Form”) at least one (1) whole calendar month
before the month in which the Company intends to terminate this Agreement (“Termination Effective Month”). The Company is
entitled to use the office and conference space on a need basis. The new rent payment or membership fee for Irvine Office is $95 per
month compared to the previous rent payment or membership fee for the New York Office of $890 per month as the General and administrative
expenses.
From
February 2019 to the present, the Company leased office space in Limassol District, Cyprus, from an unrelated party for a year. The office’s
rent payment is $1,750 per month as the General and administrative expenses.
From
February 2020, this agreement continues every year upon written request by the Company. The Company uses the office for sales and marketing
in Europe and Asia. From April 2019 to August 2022, the Company leased office space in Chelyabinsk, Russia, from an unrelated party for
an eleven (11) month term. The office’s rent payment is $500 per month, and the Company has included it in the General and administrative
expenses. From March 2020, this agreement continues on a month-to-month basis until the Company, or the lessor chooses to terminate by
the agreement’s terms by giving thirty (30) days’ notice. The Company uses the office for software development and technical
support. Effective August 2022, the Company closed its offices in Russia and relocated its team to Turkey.
As
all leases are either on a month-to-month basis or less than one (1) year term, the Company is not required to recognize assets and liabilities
for our rental leases. The Company has included all rental expenses in the General and Administrative costs.
ITEM
3.
LEGAL
PROCEEDINGS
There
is no material pending legal or governmental proceedings other than ordinary routine litigation incidental to the business. The Company
or any of its subsidiaries is a party, or their property is the subject.
ITEM
4.
MINE
SAFETY DISCLOSURES.
Not
applicable.
8
PART
II
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