Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
Not
applicable to a “smaller reporting company” as defined in Item 10(f)(1) of Regulation S-K.
ITEM 1C. CYBERSECURITY
Risk Management and Strategy
As a smaller reporting company, we currently do not
have formalized cybersecurity measures, a dedicated cybersecurity team or specific protocols in place to manage cybersecurity risks. Our
approach to cybersecurity is in the developmental stage, and we have only begun to conduct comprehensive risk assessments, establish an
incident response plan, and engage with external cybersecurity consultants for assessments or services. As of the date of this report,
we have adopted an incident response plan which governs our assessment and response upon the occurrence of a material cybersecurity incident,
including the process for informing senior management and our Board of Directors. Our Chief Executive Officer has been designated as the
lead for implanting our incident response plan.
Given our current stage of cybersecurity development,
we have not experienced any significant cybersecurity incidents to date. However, we recognize that the absence of a formalized cybersecurity
framework may leave us vulnerable to cyberattacks, data breaches and other cybersecurity incidents. Such events could potentially lead
to unauthorized access to, or disclosure of, sensitive information, disrupt our business operations, result in regulatory fines or litigation
costs and negatively impact our reputation among customers and partners.
We are in the process of evaluating our cybersecurity
needs and developing appropriate measures to enhance our cybersecurity posture. This includes considering the engagement of external cybersecurity
experts to advise on best practices, conducting vulnerability assessments and developing an incident response strategy. Our goal is to
establish a cybersecurity framework that is commensurate with our size, complexity and the nature of our operations, thereby reducing
our exposure to cybersecurity risks.
In addition, our board of directors will oversee any
cybersecurity risk management framework and a dedicated committee of our board of directors will review and approve any cybersecurity
policies, strategies and risk management practices.
Despite our efforts to improve our cybersecurity measures,
there can be no assurance that our initiatives will fully mitigate the risks posed by cyber threats. The landscape of cybersecurity risks
is constantly evolving, and we will continue to assess and update our cybersecurity measures in response to emerging threats.
Governance
Board of Directors
The audit committee of the Company’s board of
directors, with the input of management, oversees the Company’s internal controls, including internal controls designed to assess,
identify, and manage material risks from cybersecurity threats. The audit committee is informed of material risks, when applicable, from
cybersecurity threats by the Company’s Chief Executive Officer. Updates on cybersecurity matters, including material risks and threats,
are provided to the Company’s audit committee, and the audit committee provides updates to the Company’s board of directors
at regular board meetings.
Management
Under the oversight of the audit committee of the
Company’s board of directors, the Company’s Chief Executive Officer is primarily responsible for the assessment and management
of material cybersecurity risks and establishing and maintaining adequate and effective internal controls covering cybersecurity matters.
The audit committee of the Company’s board of
directors, with the assistance of the Company’s Chief Executive Officer, is responsible for overseeing the establishment and effectiveness
of controls and other procedures, including controls and procedures related to the public disclosure of material cybersecurity matters.
As of the date of this report, other than the foregoing,
the Company is not aware of any cybersecurity incidents that have materially affected or are reasonably likely to materially affect the
Company, including its business strategy, results of operations, or financial condition and that are required to be reported in this report.
For further discussion of the risks associated with cybersecurity incidents, see the cybersecurity risk factors in Item 1A. Risk Factors
in this report.
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