Item 1B. Unresolved Staff Comments
ITEM 1B. UNRESOLVED STAFF COMMENTS
Not Applicable.
ITEM 1C. CYBERSECURITY
Risk Management and Strategy
We recognize the importance of
developing, implementing and maintaining cybersecurity measures to safeguard our information and operational technologies and protect
the confidentiality, integrity and availability of our data. Our business is dependent upon our computer systems, devices, software and
networks to collect, process and store the data necessary to conduct almost all aspects of our business.
We have designed our cybersecurity
procedures based on the National Institute of Standards and Technology Cybersecurity Framework (“NIST CSF”). We have used
NIST CSF as a guide to help identify, assess and manage cybersecurity risks relative to our business, but this does not imply that our
cybersecurity program meets any particular technical standard, specification or requirement.
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We have processes in place to
assess, identify, manage and address material cybersecurity threats and incidents. These include, among other things, annual and ongoing
security awareness training for employees, mechanisms to detect and monitor unusual network activity, use of encryption and authentication
technologies, penetration testing and containment and incident response tools. We regularly assess risks from cybersecurity and technology
threats and monitor our information systems for potential vulnerabilities.
We maintain an incident response
plan with a cross-functional team comprised of members of the information technology department, senior management and other appropriate
individuals. The team is responsible for assessing and managing the cybersecurity incident response process and taking necessary corrective
actions to mitigate and/or eliminate any issues. In connection with our new digital asset treasury strategy, we intend to appoint a Chief
Information Security Officer in Fiscal 2026.
Our control over the security
posture of and ability to monitor the cybersecurity practices of third-party vendors and service providers, including Galaxy Digital and
any digital asset custodians, exchanges, or validators we utilize, is limited and there can be no assurance that we can prevent, mitigate
or remediate the risk of any compromise or failure in the cybersecurity infrastructure owned or controlled by third parties. Given our
significant digital asset holdings, any cybersecurity breach affecting our third-party service providers could have a material adverse
effect on our business, financial condition, and results of operations.
As of the filing date of this
Annual Report on Form 10-K, we are not aware of any cybersecurity incidents that have materially affected or are reasonably likely to
materially affect our business strategy, results of operations or financial condition. However, despite our efforts, we cannot eliminate
all risks from cybersecurity threats or incidents or provide assurances that we have not experienced an undetected cybersecurity incident.
For more information about these risks, see “Item 1A – Risk Factors.”
Governance
Our Board of Directors has overall
responsibility for the oversight of risk management, including cybersecurity risks. The Board of Directors receives periodic briefings
on cybersecurity matters, including key risks to the Company, recent developments and risk mitigation activities from management.
Our information technology team
is responsible for assessing and maintaining our cybersecurity risk management program and may engage third-party experts on an as-needed
basis for risk assessment and system enhancements. Our information technology team are experienced information systems security professionals
with many years of experience in the information technology field and various degrees and cybersecurity-related certifications.