What changed in this filing

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Item 1B. Unresolved Staff Comments

2024-10-15 compared with 2023-04-17 · 49 added, 13 removed, 17 unchanged (78% of the section changed)

STAFF COMMENTS

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”).

Irvine Lease, California, USA (Headquarter)

October 29, 2019, to the present, the Company leased office space at 200 Spectrum Center Drive, Suite 300, Irvine, CA 92618.

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.”

2 unchanged sentences

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

February 2019 to the present, the Company leased office space in Limassol District, Cyprus, from an unrelated party for a year.

rent payment is $1,750 per month as the General and administrative expenses.

entitled to use the office and conference space if needed.

The new rent payment or membership fee for the 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.

Limassol, Cyprus Lease, (Europe Office)

From February 2019 to July 2023, the Company leased office space in Limassol

District, Cyprus, from an unrelated party for a year.

The office’s monthly rent payment is $1,750, which is included in the general

and administrative expenses.

From July 2023 to the present, the Company leased a bigger office space in Limassol District, Cyprus, from

an unrelated party for a year.

The office’s monthly rent payment is approximately $3,500, which is included in the general and administrative

From July 2023 to the present, the Company leased office space for its CEO.

The office’s monthly rent payment is $3,500,

which is included in the general and administrative expenses.

The down payment for the lease was approximately $6,300.

The lease is for

one year and renewable two months before the term in June 2025.

Cyprus Lease, Europe (Ecastica)

October 2023 to January 2024, the Company leased office space in the Limassol District, Cyprus, for a specific purpose.

This space was

intended for our subsidiary, Alchemytech Ltd, to be established in Cyprus in March 2024.

The monthly rent payment for this office was

approximately $1,000, and the down payment for the lease was approximately $6,300.

These expenses were included in the general and administrative

Russia (Terminated)

February 2020, this agreement continues every year upon written request by the Company.

4 unchanged sentences

The office’s rent payment is $500 per month, and the Company has included it in the General and administrative

From March 2020, this agreement continues on a month-to-month basis until the Company, or the lessor chooses to terminate by

From March 2020, this agreement continues 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.

1 unchanged sentence

Effective August 2022, the Company closed its offices in Russia and relocated its team to Turkey.

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.

In April 2023, we relocated

our personnel to Kazakhstan.

Assets and Lease Liabilities

Company has entered into operating lease agreements for its facilities and equipment.

The right-of-use asset (ROU) is measured at the

present value of the lease payments over the lease term, adjusted for lease incentives, initial direct costs, and any lease payments

made at or before the commencement date.

As of December 31, 2023, the ROU:

Lease liabilities are measured at the present value

of the remaining lease payments, discounted using the Company’s incremental borrowing rate (10.00%) at the lease commencement date.

The Operating Lease Liability was estimated to be $36,419 current and $3,264 noncurrent.

The lease expense for the fiscal year ended

December 31, 2023, consists of an operating lease expense of $42,390.

Company determines the lease term as the non-cancelable period of the lease, together with periods covered by an option to extend the

lease if it is reasonably certain to be exercised and periods covered by an option to terminate the lease if it is reasonably certain

not to be exercised.

discount rate of 10.00% used to measure the lease liabilities was determined based on the Company’s incremental borrowing rate,

as the rate implicit in the lease is not readily determinable.

Company has included all rental expenses in the General and Administrative costs.

is no material pending legal or governmental proceedings other than ordinary routine litigation incidental to the business.

2 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-K

Item 1B. Unresolved Staff Comments