What changed in this filing

/stocks — the workspaceLOADING

Item 9A. Controls and Procedures

2026-02-27 compared with 2025-03-14 · 58 added, 97 removed, 215 unchanged (42% of the section changed)

1 unchanged sentence

(a) Evaluation of Disclosure Controls and Procedures

Management, with the participation of our Chief Executive Officer and the Chief Financial Officer, evaluated the effectiveness of the Company’s disclosure controls and procedures as defined in Rules 13a-15(e) and 15d-15(e) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”), as of December 31, 2024.

Based upon this evaluation, our Chief Executive Officer and the Chief Financial Officer have concluded that our disclosure controls and procedures were not effective as of December 31, 2024 due to material weaknesses in internal control over financial reporting, as described below.

Notwithstanding the ineffective disclosure controls and procedures due to the material weaknesses in internal control over financial reporting, our Chief Executive Officer and the Chief Financial Officer have concluded that that the consolidated financial statements in this Annual Report on Form 10-K present fairly, in all material respects, our financial position, results of operations and cash flows in conformity with accounting principles generally accepted in the United States of America (“U.S.

Management, with the participation of our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of the Company’s disclosure controls and procedures, as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act, as of December 31, 2025.

Based upon this evaluation, our Chief Executive Officer and Chief Financial Officer have concluded that our disclosure controls and procedures were not effective as of December 31, 2025 due to a material weakness in internal control over financial reporting, as described below.

Notwithstanding the ineffective disclosure controls and procedures due to the material weakness in internal control over financial reporting, our Chief Executive Officer and Chief Financial Officer have concluded that the consolidated financial statements in this Annual Report on Form 10-K present fairly, in all material respects, our financial position, results of operations and cash flows in conformity with accounting principles generally accepted in the United States of America (“U.S.

(b) Management’s Annual Report on Internal Control Over Financial Reporting

The management of Gogo Inc.

is responsible for establishing and maintaining adequate internal control over financial reporting as defined in Rules 13a – 15(f) and 15d – 15(f) under the Exchange Act and based upon the criteria established in Internal Control-Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (“the COSO framework”).

Our management, including our Chief Executive Officer and Chief Financial Officer, is responsible for establishing and maintaining adequate internal control over financial reporting, as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act, and based upon the criteria established in Internal Control-Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (“the COSO framework”).

Gogo’s internal control over financial reporting is designed to provide reasonable assurance regarding the reliability of financial reporting and the preparation and fair presentation of its published financial statements in accordance with U.S.

The management of Gogo, with the participation of the Company’s Chief Executive Officer and Chief Financial Officer, have assessed the effectiveness of Gogo’s internal control over financial reporting based on the COSO framework.

Based on our assessment, the Company’s management concluded that our internal control over financial reporting was not effective as of December 31, 2024, due to the material weaknesses described below.

Our assessment of the effectiveness of the Company’s internal control over financial reporting as of December 31, 2024 excludes the acquisition of Satcom Direct which was acquired on December 3, 2024, and whose financial statements constitute approximately 46% of total assets and 9% of total revenue of the consolidated financial statement amounts of the Company as of and for the year ended December 31, 2024.

Our management, with the participation of our Chief Executive Officer and Chief Financial Officer, have assessed the effectiveness of our internal control over financial reporting based on the COSO framework.

Based on our assessment, our management concluded that our internal control over financial reporting was not effective as of December 31, 2025, due to the material weakness described below.

A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of our annual or interim financial statements will not be prevented or detected on a timely basis.

Despite the exclusion of Satcom Direct from our assessment of the effectiveness of the Company’s internal control over financial reporting as of December 31, 2024, we identified a material weakness in controls over the financial close and reporting process and controls over purchase accounting as a result of the Satcom Direct acquisition.

Specifically, there were insufficient effective controls in place to ensure the completeness and accuracy of Satcom Direct’s financial reporting information that is consolidated into Gogo’s financial statements.

This material weakness was due to the following deficiencies at Satcom Direct:

• Satcom Direct had ineffective general information technology controls (“GITCs”) over relevant information technology (“IT”) systems.

The following material weakness disclosed in the Annual Report on Form 10-K for the year ended December 31, 2024 remains unremediated as of December 31, 2025:

• There were insufficient effective controls in place at Satcom Direct to ensure the completeness and accuracy of Satcom Direct’s financial reporting information that is consolidated into Gogo’s financial statements, due to the following deficiencies at Satcom Direct:

o Satcom Direct had ineffective general information technology controls (“GITCs”) over relevant information technology (“IT”) systems.

Specifically, Satcom Direct management did not design and maintain effective GITCs for information systems and applications that are relevant to the preparation of the consolidated financial statements.

Specifically, they did not design and maintain:

(i) sufficient user access controls to ensure appropriate segregation of duties and adequately restrict user and privileged access to financial applications, programs and data to appropriate company personnel and (ii) program change management controls to ensure that information technology, or IT, program and data changes affecting financial IT applications and underlying accounting records are identified, tested, authorized and implemented appropriately with appropriate segregation of duties.

• Satcom Direct’s management did not design and implement control activities necessary to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements.

We also identified a material weakness in controls over the accounting for the Satcom Direct acquisition.

Specifically, management had designed control activities over the accounting for the acquisition and related preliminary purchase price allocation for the acquired assets and liabilities performed by third-party specialists, however, management did not effectively implement them due to the timing of the acquisition.

and (ii) program change management controls to ensure that IT program and data changes affecting financial IT applications and underlying accounting records are identified, tested, authorized and implemented appropriately with appropriate segregation of duties.

o Satcom Direct’s management did not design and implement control activities necessary to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements.

Deloitte & Touche LLP, the Company’s independent registered public accounting firm, has issued an attestation report on our internal control over financial reporting as of December 31, 2025, which report is included on Page 100 of this Annual Report on Form 10-K under the caption entitled “Report of Independent Registered Public Accounting Firm.”

Remediation Plan for Material Weaknesses in Internal Control over Financial Reporting

Remediation of the identified material weaknesses and strengthening our internal control environment will require a substantial effort throughout 2025.

Management has commenced its remediation efforts over the material weaknesses described above as follows:

• Designing and implementing controls over Satcom Direct’s GITCs relating to user access and program change management over certain IT systems that support financial reporting processes at Satcom Direct.

• Designing and implementing internal controls over financial reporting for processes specific to Satcom Direct.

• Implementing the controls the Company has designed related to complex accounting transactions, including those related to acquisitions, such as, the review of third-party specialists’ work and the reasonableness of key assumptions, methodologies, and underlying data used in the accounting and purchase price allocation.

• Recruiting additional qualified personnel with expertise in public company financial reporting, accounting and internal controls to strengthen our accounting function.

While we believe the steps taken to date and those planned for implementation will improve the effectiveness of our internal control over financial reporting, we have not completed all remediation efforts identified herein.

Accordingly, as we continue to monitor the effectiveness of our internal control over financial reporting in the areas affected by the material weaknesses described above, we have performed and will continue to perform additional procedures and to employ additional appropriate tools and resources.

We will test the ongoing operating effectiveness of the new and existing controls in future periods.

The material weaknesses cannot be considered completely remediated until the applicable controls have been implemented and management has concluded, through testing, that these controls are operating effectively.

Remediation Plan for Material Weakness in Internal Control over Financial Reporting

During the year ended December 31, 2025, with the oversight of the Audit Committee of our Board of Directors, we began implementing a remediation plan to address the material weakness described above.

Action items include the following:

• We expanded our finance and accounting team, including hiring additional individuals with the requisite public company financial reporting, accounting, and internal control knowledge and experience.

• We designed and implemented effective GITCs related to user access and change management over relevant Satcom Direct’s IT systems.

While we believe that our efforts have improved our internal control over financial reporting, remediation of the material weakness as of December 31, 2025 is expected to require further strengthening of our internal control environment and substantial effort throughout 2026, including:

• Continuing to design and implement internal control over financial reporting for processes specific to Satcom Direct.

• Migrating from or enhancing certain legacy Satcom Direct IT systems to allow for the ability to obtain sufficiently reliable information and facilitate the effective design, implementation and operating effectiveness of relevant internal control over financial reporting.

• Migrating from or enhancing certain legacy Satcom Direct IT systems to improve functionality and sufficiently enforce segregation of duties, including segregation of duties related to the posting and review of manual journal entries.

We will test the effectiveness of the new and existing controls in future periods.

The material weakness cannot be considered completely remediated until the applicable controls have been implemented and management has concluded, through testing, that these controls are operating effectively.

Previously Reported Material Weakness

During the year ended December 31, 2025, we implemented controls related to complex accounting transactions, including the review of third-party specialists’ work and the reasonableness of key assumptions, methodologies and underlying data.

This remediation plan was aimed at addressing a separate material weakness in internal control over financial reporting, which existed as of December 31, 2024, as disclosed in our Annual Report on Form 10-K for the fiscal year ended December 31, 2024, relating to controls over the accounting for the Satcom Direct acquisition.

As a result of these remediation steps in 2025, this material weakness in internal control over financial reporting no longer existed as of December 31, 2025.

Except for the identification of the material weaknesses described above, there have been no changes to our internal control over financial reporting in connection with the evaluation required by Rules 13a-15(f) and 15d-15(f) under the Exchange Act during the most recent fiscal quarter that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

Except as described above, there have been no changes to our internal control over financial reporting, in connection with the evaluation required by Rules 13a-15(f) and 15d-15(f) under the Exchange Act, during the most recent fiscal quarter that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.

Other Information

(a) Item 5.02 Departure of Directors of Certain Officers;

Election of Directors;

Appointment of Certain Officers;

Compensatory Arrangements of Certain Officers.

Inducement Awards

As discussed above, on December 3, 2024, the Company completed the previously announced acquisition of 100% of the issued and outstanding equity interests in Satcom Direct, pursuant to the terms of the Purchase Agreement.

In connection with the acquisition and as an inducement for Messrs.

Christopher Moore and Zachary Cotner (each an “Executive” and together, the “Executives”) to join the Company as our new Chief Executive Officer and Chief Financial Officer, respectively, the Company granted certain inducement awards pursuant to Nasdaq Rule 5635(c)(4) (the “Inducement Awards”) to the Executives, to promote their retention and create an alignment of interests between them and the Company’s shareholders.

The Inducement Awards were granted by the Compensation Committee of our Board of Directors and included the following awards:

(i) 1,000,000 time-vesting restricted stock units (“RSUs”) and 1,000,000 performance stock units (“PSUs”) (representing the target number of shares in the case of PSUs) to Mr.

and (ii) 50,000 RSUs and 50,000 PSUs (representing the target number of shares in the case of PSUs) to Mr.

The RSUs will vest in equal annual installments over the five-year period following the Closing.

The PSUs are subject to performance-based vesting and will vest when the performance-based vesting conditions are met.

The PSUs are divided into two equal tranches.

The first tranche will vest on the earlier of (i) the date the value of the Common Stock equals or exceeds $20.00 per share for a period of 90 consecutive trading days following the six-month anniversary of the Closing, and (ii) the date the Company consummates a change in control pursuant to which the price per share of Common Stock in connection with such change in control (the “Change in Control Price”) equals or exceeds $20.00 per share.

The second tranche will vest on the earlier of (i) the date the value of the Common Stock equals or exceeds $25.00 per share for a period of 90 consecutive trading days following the six-month anniversary of the Closing, and (ii) the date the Company consummates a change in control pursuant to which the Change in Control Price equals or exceeds $25.00 per share.

Vesting of the PSUs and RSUs is conditioned on

the Executive’s continued employment through the applicable vesting date, subject to accelerated vesting upon the occurrence of specified employment termination and change in control events.

Each of the Inducement Awards was granted consistent with the terms of each Executive’s employment agreement previously entered into with Gogo Business Aviation LLC.

Though not awarded pursuant to the Company’s 2024 Omnibus Equity Incentive Plan (the “2024 Plan”), the Inducement Awards have been issued subject to the terms and conditions of the 2024 Plan.

The foregoing summary of the Inducement Awards is qualified in its entirety by reference to the 2024 Plan and the applicable award agreements, which are filed herewith as Exhibits 10.53 and 10.54 respectively, to this Annual Report on Form 10-K and are incorporated herein by reference.

(b) During the fiscal quarter ended December 31, 2024, none of our directors or officers adopted or terminated a “Rule 10b5-1 trading arrangement” or “non-Rule 10b5-1 trading arrangement” as such terms are defined in Item 408 of Regulation S-K.

On December 15, 2025 , director (and then-Executive Chair) Oakleigh Thorne adopted a Rule 10b5-1 trading arrangement, which is intended to satisfy the affirmative defense of Rule 10b5-1(c) under the Exchange Act.

The arrangement provides for the potential sale of up to 325,409 shares of the Company’s common stock and expires on February 15, 2027 , unless earlier terminated in accordance with its terms.

No sales may occur under the arrangement until August 6 th , 2026, presumably after the Company’s Q2 2026 earnings release.

The plan is intended to facilitate certain estate and other financial planning initiatives, and the minimum sale price under the plan is substantially higher than the closing price of the Company’s common stock on the date of this Annual Report on Form 10-K.

Except as described above, during the fiscal quarter ended December 31, 2025, none of our directors or officers adopted or terminated a “Rule 10b5-1 trading arrangement” or “non-Rule 10b5-1 trading arrangement” as such terms are defined in Item 408 of Regulation S-K.

Disclosure Regarding Foreign Jurisdictions that Prevent Inspections

5 unchanged sentences

and subsidiaries (the "Company") as of December 31, 2025, based on criteria established in Internal Control — Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (COSO).

In our opinion, because of the effect of the material weaknesses identified below on the achievement of the objectives of the control criteria, the Company has not maintained effective internal control over financial reporting as of December 31, 2024, based on criteria established in Internal Control — Integrated Framework (2013) issued by COSO.

We have also audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the consolidated financial statements as of and for the year ended December 31, 2024, of the Company and our report dated March 14, 2025, expressed an unqualified opinion on those financial statements.

As described in Management’s Annual Report on Internal Control over Financial Reporting, management excluded from its assessment the internal control over financial reporting at Satcom Direct, LLC and certain of its affiliates and subsidiaries (collectively, “Satcom Direct”), which were acquired on December 3, 2024, and whose financial statements constitute 46% of total assets and 9% of total revenue of the consolidated financial statement amounts as of and for the year ended December 31, 2024.

Accordingly, our audit did not include the internal control over financial reporting at Satcom Direct.

In our opinion, because of the effect of the material weakness identified below on the achievement of the objectives of the control criteria, the Company has not maintained effective internal control over financial reporting as of December 31, 2025, based on criteria established in Internal Control — Integrated Framework (2013) issued by COSO.

We have also audited, in accordance with the standards of the Public Company Accounting Oversight Board (United States) (PCAOB), the consolidated financial statements as of and for the year ended December 31, 2025, of the Company and our report dated February 27, 2026, expressed an unqualified opinion on those financial statements.

Basis for Opinion

14 unchanged sentences

Also, projections of any evaluation of effectiveness to future periods are subject to the risk that controls may become inadequate because of changes in conditions, or that the degree of compliance with the policies or procedures may deteriorate.

Material Weaknesses

Material Weakness

A material weakness is a deficiency, or a combination of deficiencies, in internal control over financial reporting, such that there is a reasonable possibility that a material misstatement of the company's annual or interim financial statements will not be prevented or detected on a timely basis.

The following material weaknesses have been identified and included in management's assessment.

Management identified a material weakness in controls over the financial close and reporting process and purchase accounting controls as a result of the Satcom Direct acquisition.

The following material weakness has been identified and included in management's assessment.

A material weakness exists in controls over the financial close and reporting process as a result of the Satcom Direct acquisition in 2024.

Specifically, there were insufficient effective controls in place to ensure the completeness and accuracy of Satcom Direct's financial reporting information that is consolidated into the Company's financial statements.

3 unchanged sentences

Specifically, they did not design and maintain:

(i) sufficient user access controls to ensure appropriate segregation of duties and adequately

restrict user and privileged access to financial applications, programs and data to appropriate company personnel and (ii) program change management controls to ensure that information technology, or IT, program and data changes affecting financial IT applications and underlying accounting records are identified, tested, authorized and implemented appropriately with appropriate segregation of duties.

• Satcom Direct management did not design and implement control activities necessary to provide reasonable assurance regarding the reliability of financial reporting and the preparation of financial statements.

Management also identified a material weakness in controls over the accounting for the Satcom Direct acquisition.

These material weaknesses were considered in determining the nature, timing, and extent of audit tests applied in our audit of the consolidated financial statements as of and for the year ended December 31, 2024, of the Company, and this report does not affect our report on such financial statements.

This material weakness was considered in determining the nature, timing, and extent of audit tests applied in our audit of the consolidated financial statements as of and for the year ended December 31, 2025, of the Company, and this report does not affect our report on such financial statements.

/s/ Deloitte & Touche, LLP

Chicago, Illinois

March 14, 2025

February 27, 2026

Directors, Executive Of ficers and Corporate Governance

40 unchanged sentences

Amended and Restated Bylaws (incorporated by reference to Exhibit 3.1 to Form 8-K filed on August 2, 2023 (File No.

Certificate of Designations of Series A Preferred Stock of Gogo Inc., as filed with the Secretary of State of the State of Delaware on September 23, 2020 (incorporated by reference to Exhibit 3.1 to Form 8-K filed on September 23, 2020 (File No.

Form of Common Stock Certificate (incorporated by reference to Exhibit 4.1 to Gogo Inc.

26 unchanged sentences

Amended and Restated Supply and Product Support Agreement, dated as of March 31, 2023, by and between Gogo Business Aviation LLC and Hughes Network Systems, LLC (incorporated by reference to Exhibit 10.1.1 to Form 10-Q filed on May 3, 2023 (File No.

Amended and Restated Employment Agreement, dated March 27, 2024, between Gogo Inc.

and Oakleigh Thorne (incorporated by reference to Exhibit 10.1 to Form 8-K filed on April 2, 2024 (File No.

Employment Agreement, effective as of March 11, 2023, by and between Gogo Business Aviation LLC and Jessica Betjemann (incorporated by reference to Exhibit 10.1 to Form 8-K filed on February 14, 2023 (File No.

Amendment Number One to Employment Agreement, dated November 27, 2024, between Gogo Inc.

and Jessica Betjemann

Employment Agreement, effective as of November 2, 2022, by and between Gogo Business Aviation LLC and Crystal Gordon (incorporated by reference to Exhibit 10.2.21 to Form 10-K filed on February 28, 2023 (File No.

2 unchanged sentences

Employment Agreement, dated November 13, 2024, between Gogo Inc.

and Christopher Moore

and Christopher Moore (incorporated by reference to Exhibit 10.16 to Form 10-K filed on March 14, 2025 (File No.

Change in Control Severance Agreement, dated November 13, 2024, between Gogo Inc.

and Christopher Moore

and Christopher Moore (incorporated by reference to Exhibit 10.17 to Form 10-K filed on March 14, 2025 (File No.

Retention Bonus Agreement, dated November 13, 2024, between Gogo Inc.

and Christopher Moore

and Christopher Moore (incorporated by reference to Exhibit 10.18 to Form 10-K filed on March 14, 2025 (File No.

Employment Agreement, dated November 27, 2024, between Gogo Inc.

and Zachary Cotner

and Zachary Cotner (incorporated by reference to Exhibit 10.19 to Form 10-K filed on March 14, 2025 (File No.

Retention Bonus Agreement, dated November 27, 2024, between Gogo Inc.

and Zachary Cotner

and Zachary Cotner (incorporated by reference to Exhibit 10.20 to Form 10-K filed on March 14, 2025 (File No.

Change in Control Severance Agreement, dated November 27, 2024, between Gogo Inc.

and Zachary Cotner

and Zachary Cotner (incorporated by reference to Exhibit 10.21 to Form 10-K filed on March 14, 2025 (File No.

Employment Agreement, dated November 13, 2024, between Gogo Inc.

and Hayden Olson

and Hayden Olson (incorporated by reference to Exhibit 10.22 to Form 10-K filed on March 14, 2025 (File No.

Change in Control Severance Agreement, dated November 13, 2024, between Gogo Inc.

and Hayden Olson

and Hayden Olson (incorporated by reference to Exhibit 10.23 to Form 10-K filed on March 14, 2025 (File No.

Retention Bonus Agreement, dated November 13, 2024, between Gogo Inc.

and Hayden Olson

Employment Agreement, dated January 13, 2025, between Gogo Inc.

and Mike Begler

Change in Control Severance Agreement, dated January 13, 2025, between Gogo Inc.

and Mike Begler

Separation Agreement, dated January 13, 2025, between Gogo Inc.

and Sergio Aguirre

Consulting Agreement, dated January 13, 2025, between Gogo Inc.

and Sergio Aguirre

and Hayden Olson (incorporated by reference to Exhibit 10.24 to Form 10-K file don March 14, 2025 (File No.

2013 Omnibus Incentive Plan (incorporated by reference to Exhibit 10.5 to Gogo Inc.

7 unchanged sentences

2024 Omnibus Equity Incentive Plan (incorporated by reference to Exhibit 10.1 to Form 8-K filed on June 6, 2024 (File No.

Form of Restricted Stock Unit Agreement for Gogo 2024 Omnibus Equity Incentive Plan

Old Form of Restricted Stock Unit Agreement for Gogo 2024 Omnibus Equity Incentive Plan (incorporated by reference to Exhibit 10.34 to Form 10-K filed on March 14, 2025 (File No.

New Form of Restricted Sock Unit Agreement for Gogo 2024 Omnibus Equity Incentive Plan

2024 Employee Stock Purchase Plan (incorporated by reference to Exhibit 10.2 to Form 8-K filed on June 6, 2024 (File No.

26 unchanged sentences

Gogo Intermediate Holdings LLC, HPS Investment Partners, LLC, as administrative agent, and the lenders party thereto (incorporated by reference to Exhibit 10.2 to Form 8-K filed on December 9, 2024 (File No.

Lock-Up Agreement, dated as of December 3, 2024 (incorporated by reference to Exhibit 10.3 to Form 8-K filed on December 9, 2024 (File No.

Restricted Stock Unit Agreement (Inducement), dated as of March 14, 2025, by and between the Company and Christopher Moore (incorporated by reference to Exhibit 99.1 to Form S-8 filed on March 14, 2025 (File No.

Restricted Stock Unit Agreement (Inducement), dated as of March 14, 2025, by and between the Company and Zachary Cotner (incorporated by reference to Exhibit 99.2 to Form S-8 filed on March 14, 2025 (File No.

Insider Trading Policy

Insider Trading Policy (incorporated by reference to Exhibit 19 to Form 10-K filed on March 14, 2025 (File No.

List of Subsidiaries

17 unchanged sentences

Pursuant to the requirements of Section 13 or 15(d) of the Securities Exchange Act of 1934, Gogo Inc.

(the registrant) has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized, on March 14, 2025.

(the registrant) has duly caused this report to be signed on its behalf by the undersigned, thereunto duly authorized, on February 27, 2026.

/s/ Christopher Moore

9 unchanged sentences

Pursuant to the requirements of the Securities Exchange Act of 1934, as amended, this report has been signed below by the following persons on behalf of Gogo Inc.

and in the capacities indicated, on March 14, 2025.

and in the capacities indicated, on February 27, 2026.

/s/ Christopher Moore

10 unchanged sentences

(Principal Accounting Officer)

/s/ Michael Abad-Santos

Michael Abad-Santos

/s/ Mark Anderson

Mark Anderson

/s/ Robert L.

Lead Independent Director

2 unchanged sentences

Michele Coleman Mayes

/s/ Christopher D.

Christopher D.

/s/ Michael Minihan

Michael Minihan

/s/ Oakleigh Thorne

Executive Chair of the Board

Chair of the Board

Oakleigh Thorne

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 9A. Controls and Procedures