Unresolved Staff Comments
+Added: Not applicable.
Cybersecurity
−Removed: board administers its cybersecurity risk oversight function directly through our audit committee.
−Removed: Our audit committee has primary responsibility
−Removed: for overseeing our risk assessment and risk management policies (including with respect to cybersecurity matters).
−Removed: Our audit committee
−Removed: regularly discusses with management, counsel, and auditors the Company’s major risk exposures.
−Removed: This includes potential financial
−Removed: impact on the Company and the steps taken to monitor and control those risks.
−Removed: Additionally, our board is informed regarding the risks
−Removed: facing the Company and coordinates with management and our cybersecurity team to ensure our board receives regular risk assessment updates
−Removed: from management.
−Removed: retain Techneto, Inc.
−Removed: d/b/a CyberTeam (“CyberTeam”), a third party vendor that reports directly to our president and chief
−Removed: operating officer, to be responsible for identifying, assessing and managing the Company’s risks from cybersecurity threats.
−Removed: has been with the Company since its inception and has over 25 years of experience in cybersecurity.
−Removed: provides our board and executive leadership team with periodic updates about our cybersecurity program and material risks.
−Removed: This includes
−Removed: updates on cybersecurity practices, programs, and the status of projects designed to strengthen internal cybersecurity and data protection.
−Removed: Management and Strategy
−Removed: for identifying and assessing cybersecurity risks
−Removed: management, with the support of CyberTeam, monitors current events and trends related to cybersecurity and assesses any potential impact
−Removed: on current systems and operations.
−Removed: Third-party partners who are in possession of our confidential information are generally required
−Removed: to notify us in the event of a cybersecurity incident within their systems that have, or are reasonably likely to, compromise the security
−Removed: of such information.
−Removed: When appropriate, we enlist CyberTeam to perform a risk and security assessment of the cybersecurity protocols and
−Removed: procedures of critical third-party partners.
−Removed: for managing cybersecurity risks
−Removed: tracks risks and incidents related to cybersecurity until the risk is mitigated to an acceptable level or fully remediated.
−Removed: are identified, CyberTeam oversees mitigation plans with the risk owner which are communicated to necessary teams and remediation steps
−Removed: for incorporating cybersecurity risks into the overall risk management process
−Removed: process for identifying, assessing, and managing risks related to cybersecurity generally involves CyberTeam regularly meeting with our
−Removed: executive leadership team, and when appropriate, our board and/or audit committee to discuss cybersecurity related risks identified and
−Removed: the potential likelihood and severity of each risk.
−Removed: we are not aware of any risks from cybersecurity threats, or from previous cybersecurity incidents, that have materially affected or
−Removed: are reasonably likely to materially affect the Company.
−Removed: corporate offices are located at 360 Madison Avenue, 25th Floor, New York, NY 10017, which is leased through our parent corporation PAVmed
−Removed: The lease for this space is for seven years and eight months, starting on February 1, 2023, and may not be terminated prior to expiration
−Removed: of its stated term, except in limited circumstances due to misconduct by our landlord.
−Removed: Company has a lease agreement for its CLIA laboratory in California with 21,019 square feet, which has a remaining term expiring December 31, 2024.
−Removed: also have lease agreements for our Lucid Test Centers in various locations in Arizona, California, Colorado, Florida, Idaho, Illinois,
−Removed: Nevada, Ohio, Texas and Utah that in the aggregate approximate 15,048 square feet.
−Removed: At this time, we consider our facility space to be
−Removed: commensurate with our current operations.
−Removed: Notwithstanding, we may obtain additional office space in the future, as warranted by our business
+Added: Our board administers its cybersecurity
+Added: risk oversight function directly through our audit committee.
+Added: Our audit committee has primary responsibility for overseeing our risk
+Added: assessment and risk management policies (including with respect to cybersecurity matters).
+Added: Our audit committee regularly discusses with
+Added: management, counsel, and auditors the Company’s major risk exposures.
+Added: This includes potential financial impact on the Company and the
+Added: steps taken to monitor and control those risks.
+Added: Additionally, our board is informed regarding the risks facing the Company and coordinates
+Added: with management and our cybersecurity team to ensure our board receives regular risk assessment updates from management.
+Added: We retain Techneto, Inc.
+Added: CyberTeam (“CyberTeam”), a third party vendor that reports directly to our president and chief operating officer, to be responsible
+Added: for identifying, assessing and managing the Company’s risks from cybersecurity threats.
+Added: CyberTeam has been with the Company since
+Added: the Company’s inception and has over 25 years of experience in cybersecurity.
+Added: CyberTeam provides our board
+Added: and executive leadership team with periodic updates about our cybersecurity program and material risks.
+Added: This includes updates on cybersecurity
+Added: practices, programs, and the status of projects designed to strengthen internal cybersecurity and data protection.
+Added: Risk Management and Strategy
+Added: Processes for identifying and assessing cybersecurity
+Added: Senior management, with the support
+Added: of CyberTeam, monitors current events and trends related to cybersecurity and assesses any potential impact on current systems and operations.
+Added: Third-party partners who are in possession of our confidential information are generally required to notify us in the event of a cybersecurity
+Added: incident within their systems that have, or are reasonably likely to, compromise the security of such information.
+Added: When appropriate,
+Added: we enlist CyberTeam to perform a risk and security assessment of the cybersecurity protocols and procedures of critical third-party partners.
+Added: Processes for managing cybersecurity risks
+Added: CyberTeam tracks risks and incidents
+Added: related to cybersecurity until the risk is mitigated to an acceptable level or fully remediated .
+Added: When risks are identified, CyberTeam
+Added: oversees mitigation plans with the risk owner which are communicated to necessary teams and remediation steps are taken.
+Added: Processes for incorporating cybersecurity risks
+Added: into the overall risk management process
+Added: Our process for identifying,
+Added: assessing, and managing risks related to cybersecurity generally involves CyberTeam regularly meeting with our executive leadership team,
+Added: and when appropriate, our board and/or audit committee to discuss cybersecurity related risks identified and the potential likelihood
+Added: and severity of each risk.
+Added: Currently, we are not aware of
+Added: any risks from cybersecurity threats, or from previous cybersecurity incidents, that have materially affected or are reasonably likely
+Added: to materially affect the Company.
+Added: Our corporate offices are located
+Added: at 360 Madison Avenue, 25th Floor, New York, NY 10017, which is leased through our parent corporation PAVmed Inc.
+Added: The lease for this
+Added: space is for seven years and eight months, starting on February 1, 2023, and may not be terminated prior to expiration of its stated
+Added: term, except in limited circumstances due to misconduct by our landlord.
+Added: The Company has a lease agreement
+Added: for its CLIA laboratory in California with 21,019 square feet, which has a remaining term expiring December 31, 2027.
+Added: We also have lease
+Added: agreements for our Lucid Test Centers in various locations in Arizona, California, Colorado, Florida, Georgia, Idaho, Michigan, Nevada,
+Added: Texas and Utah that in the aggregate approximate 5,764 square feet.
+Added: At this time, we consider our facility space to be commensurate with
+Added: our current operations.
+Added: Notwithstanding, we may obtain additional office space in the future, as warranted by our business operations.
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.