What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-03-24 compared with 2024-03-15 · 71 added, 52 removed, 6 unchanged (95% of the section changed)

2 unchanged sentences

CYBERSECURITY

In support of our commitment to cybersecurity,

we employ a comprehensive strategy which is intended to protect our digital infrastructure, which strategy is supported by both management

and our Board of Directors.

Our Board of Directors is responsible for overseeing our risk management activities in general, and certain

of our Board committees assists the Board of Directors in the role of risk oversight.

The full Board of Directors receives an update on

the Company’s risk management process and the risk trends related to cybersecurity at least annually.

At the management level, leading our efforts is

a cybersecurity team that reports directly to our Senior Vice President.

This team conducts manual and automated testing on our systems,

with the goal of identifying vulnerabilities and proactively strengthening our defenses.

We believe that embracing a multi-layered defense

approach, will help us recognize and address the dynamic nature of cyber threats.

At IPM, cybersecurity is at the core of our business operations and

an integral part of our commitment to delivering secure, compliant, and resilient technology solutions to customers operating in highly

regulated industries.

Prior to the Transactions, the Company employed a comprehensive strategy with respect to cybersecurity, which was

supported by both management and our Board.

Historically, our Board was responsible for overseeing our risk management activities in general,

and certain of our Board committees assisted the Board in the role of risk oversight.

The operations team prior to the Transactions conducted

manual and automated testing of our systems, with the goal of identifying vulnerabilities and proactively strengthening our defenses.

Following the Transactions,

in order to support our comprehensive range of IT-related services and digital infrastructure, we have embraced a multi-layered defense

approach, which helps us recognize and address the dynamic nature of cyber threats.

By integrating diverse security measures, we aim to

fortify our infrastructure against a spectrum of potential risks, adapting to the ever-evolving cybersecurity landscape.

Our cybersecurity team performs tests, encompassing

vulnerability assessments, penetration testing, and threat simulations.

The results derived from these assessments are prioritized and

integrated into the workflow of our development and operations teams to ensure that identified vulnerabilities and insights gleaned from

the tests are promptly addressed.

We also have an established process led by our Senior Vice President governing our assessment, response

and notifications internally and externally upon the occurrence of a cybersecurity incident.

Depending on the nature and severity of

an incident, this process provides for escalating notification to our Chief Executive Officer and the Board of Directors.

To enhance our defense mechanisms, we leverage

third-party edge security tools.

These tools play a crucial role in actively monitoring and mitigating potential threats to our sites

and products, which we believe contributes to our security infrastructure.

Our development teams also use proactive measures such as

“Security as Code” to make sure that vulnerabilities are protected against at a deeper level, in addition to cloud-based

security tools.

Recognizing the pivotal role of our personnel

in cybersecurity, we also conduct proactive training sessions covering essential topics such as data handling practices and email phishing

These initiatives are designed to empower our workforce to serve as a human firewall, augmenting our overall security posture.

Additionally, we also think about data handling from a code and infrastructure level, incorporating encryption measures in transit and

at rest to safeguard both internal and customer data.

We further employ a proactive backup strategy, ensuring rapid system restoration

in the event of disruptions.

This measure minimizes downtime and underscores our commitment to business continuity and customer service

An integral part of our cybersecurity readiness

is an annual external IT audit that evaluates various aspects of our cybersecurity framework.

This measure ensures that our defenses

align with industry best practices and facilitates continuous improvement.

The results of this audit are reviewed by the audit committee

of the Board of Directors, allowing such committee to assist in and make recommendations on our management’s cybersecurity controls.

fortify our infrastructure against a spectrum of potential risks and adapt to the ever-evolving cybersecurity landscape.

Our cybersecurity strategy is proactively designed

to protect our digital infrastructure, customer environments, and business continuity.

This approach is supported by our management and

Board, with structured oversight to ensure compliance with evolving regulatory, risk, and industry best practices.

Proactive Security Measures and Threat Management

We employ a multi-layered defense strategy, leveraging

advanced threat intelligence, automation, and security analytics to proactively detect, prevent, and respond to cyber threats.

security practices include:

threat monitoring and response utilizing real-time security operations centers and next-generation endpoint detection and response to

rapidly identify and neutralize threats;

vulnerability assessments and penetration testing conducted through automated and manual assessments with prioritized remediation workflows

to enhance security across infrastructure, applications, and client environments;

trust security architecture, which implements strict identity verification, least privilege access and network segmentation to reduce

attack surfaces and prevent lateral movement of threats;

● partnerships

with leading cybersecurity firms for independent security audits, risk assessments, and compliance rev iews as described below.

Recognizing that human factors play a critical

role in cybersecurity, our workforce and compliance training includes comprehensive security awareness program.

All employees undergo

quarterly security training, covering data protection, insider threat mitigation, phishing awareness, and compliance best practices.

Additionally,

we implement strict enforcement of multi-factor authentication, just-in-time access controls, and continuous user behavior monitoring.

Incident Response and Business Continuity

Our incident response framework follows a structured

escalation and notification process focused on rapid containment, mitigation, and recovery from cybersecurity incidents.

protocols include:

detection and response workflows to leverage rapid assessment detection technology to detect

breaches in real time;

of critical incidents to our Chief Executive Officer, President, and Chief Operating Officer

and the Board based on severity and regulatory reporting requirements;

backup and disaster recovery, which implement immutable backups, air-gapped storage, and

rapid failover solutions to protect data integrity and minimize downtime in case of cyber

Both management and the Board are actively involved

in the oversight of risks from cybersecurity threats.

Our information security program is designed to ensure that management and the Board

are adequately informed about, and provided with the tools necessary to monitor, (i) material risks from cybersecurity threats and (ii)

our efforts related to the prevention, detection, mitigation, and remediation of cybersecurity incidents.

Role of the Board

Our Board oversees cybersecurity risk as part

of our enterprise risk management strategy.

The Board receives comprehensive cybersecurity updates from our President at least quarterly

to inform our directors of evolving threats and regulatory developments.

We undergo regular independent audits, cybersecurity risk assessments,

and compliance reviews to validate our security posture, and our Audit Committee receives annual reports regarding our ongoing security

Role of Management

At the management level, our Chief Information

Security Officer (“CISO”) leads cybersecurity initiatives and reports regularly to the President on security posture, risk

trends, and key incidents.

Our President is a seasoned technology and business leader with over 20 years of experience in managed IT services

and global scale multi-site private cloud datacenter operations.

His background and experience provide him with expertise regarding data

privacy and security, vulnerability management, security operations, and application security.

In addition, our Chief Operating Officer

has many years of experience with managed IT cyber application delivery.

We face risks from cybersecurity threats that

could have a material adverse effect on its business, financial condition, results of operations, cash flows or reputation.

we have not experienced any cyber incidents that have had an adverse material effect on our business, financial condition, results of

operations, or cash flows.

See “Risk Factors – Risks Related to Our Business – Security breaches, computer viruses

and cybersecurity incidents could harm our business, results of operations or financial condition.”

Our principal executive office is located at

30 Jericho Executive Plaza in Jericho, New York 11753.

The lease for the 30 Jericho Executive Plaza office space expires on November

We currently do not own any real property.

have not experienced any risks from cybersecurity threats that have materially affected, or are reasonably likely to materially affect,

our business strategy, financial condition, results of operations, or cash flows.

See “ Risk Factors – Risks Related to

Our Business – We could be adversely affected by information security breaches or cyber security attacks .”

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