UNRESOLVED STAFF COMMENTS
−Removed: 41 | 2024 10-K
CYBERSECURITY
5 unchanged sentences
These risk assessments include identification of reasonably foreseeable internal and external risks, the likelihood and potential damage that could result from such risks, and the sufficiency of existing policies, procedures, systems, and safeguards in place to manage such risks.
−Removed: Following these risk assessments, we implement and maintain reasonable safeguards to minimize identified risks;
−Removed: reasonably address any identified gaps in existing safeguards;
−Removed: and regularly monitor the effectiveness of our safeguards.
+Added: Following these risk assessments, we implement and maintain reasonable safeguards to minimize identified risks, reasonably address any identified gaps in existing safeguards, and regularly monitor the effectiveness of our safeguards.
We devote significant resources and designate high-level personnel, including our Chief Security Officer and Chief Information Officer, to manage the risk assessment and mitigation process.
−Removed: We have implemented technical solutions that are designed to protect our information systems from cybersecurity threats, including firewalls, intrusion prevention and detection systems, antimalware functionality, and access controls.
+Added: We have implemented technical solutions that are designed to protect our information systems from cybersecurity threats, including firewalls, intrusion prevention and detection systems, anti-malware functionality, and access controls.
We regularly evaluate, monitor, and improve these solutions.
4 unchanged sentences
We work with our third-party suppliers and service providers to address the use of appropriate security measures in connection with their work with us.
+Added: We evaluate cybersecurity incidents individually and in the aggregate to assess materiality.
Like any other technology company operating in today’s environment, we have experienced incidents in the past and may experience them in the future.
However, we have not experienced any cybersecurity incidents that have been determined to be material.
−Removed: For additional information regarding risks from cybersecurity threats, and their effect on our company, including our business strategy, results of operations, or financial condition, please refer to “Item 1A.
+Added: For additional information regarding risks from cybersecurity threats, and their effect on our company, including our business strategy, results of operations, or financial condition, please see Item 1A.
Risk Factors, “Risks Related to Our Business, Operations, and Industry—Breaches of our security systems or products, systems failures, interruptions, delays in service, catastrophic events, and resulting interruptions in the availability of our systems or those of our customers, suppliers, or business partners, could expose us to losses.
−Removed: One of the key functions of our Board of Directors is informed oversight of our risk management process, including risks from cybersecurity threats.
+Added: One of the key functions of our Board of Directors is informed oversight of our risk management processes, including risks from cybersecurity threats.
Our Board of Directors is responsible for monitoring and assessing strategic risk exposure, and our executive officers are responsible for the day-to-day management of the material risks we face.
Our Board of Directors administers its cybersecurity risk oversight function directly as a whole, as well as through the Security Committee.
+Added: 45 | 2025 10-K
Our Chief Security Officer and our Chief Information Officer report to our Security Committee, which oversees monitoring and incident response, risk mitigation, supply chain security, physical security, product security, insider trust, and other security-related items, and are primarily responsible to assess and manage our material risks from cybersecurity threats.
Our Chief Security Officer and Chief Information Officer have combined relevant experience of more than 45 years, including over 20 years in cybersecurity , and they oversee our cybersecurity policies and processes, including those described in “Risk Management and Strategy” above.
−Removed: Our Chief Security Officer monitors and stays informed about prevention, detection, mitigation, and remediation efforts through regular communication and reporting from our security team, and through the use of technological tools and software and results from third party assessments.
+Added: Our Chief Security Officer monitors and stays informed about prevention, detection, mitigation, and remediation efforts through regular communication and reporting from our security team, the use of technological tools and software, and results from third-party assessments.
Our Chief Security Officer and Chief Information Officer provide quarterly briefings to the Security Committee regarding our company’s cybersecurity risks and activities, including any recent cybersecurity incidents and related responses, cybersecurity systems testing, activities of third parties, and the like.
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.