What changed in this filing

/stocks — the workspaceLOADING

Item 1B. Unresolved Staff Comments

2025-03-21 compared with 2024-02-28 · 30 added, 28 removed, 2 unchanged (97% of the section changed)

1 unchanged sentence

CYBERSECURITY

We maintain a comprehensive process for identifying,

assessing, and managing material risks from cybersecurity threats as part of our broader risk management system and processes.

follow the security industry and global threat trends, and our dedicated privacy, safety, and security professionals oversee cybersecurity

risk management and mitigation, incident prevention, detection, and remediation.

Our team consists of professionals with deep cybersecurity

expertise across multiple industries, including our Information Security & Quality Manager.

Our executive leadership team, along with

input from the above professionals, are responsible for our overall enterprise risk management process and regularly consider cybersecurity

risks in the context of other material risks to the Company.

As part of our cybersecurity risk management system,

we track and log privacy and security incidents across Neonode, our vendors, and other third-party service providers to remediate and

resolve any such incidents.

Significant incidents are reviewed regularly by a cross-functional team to determine whether further escalation

is appropriate.

Any incident assessed as potentially being or potentially becoming material is immediately escalated for further assessment,

and then reported to designated members of our senior management.

We consult with outside counsel as appropriate, including on materiality

analysis and disclosure matters, and our senior management makes the final materiality determinations and disclosure and other compliance

The Board of Directors has oversight responsibility

for risks and incidents relating to cybersecurity threats, including compliance with disclosure requirements, cooperation with law enforcement,

and related effects on financial and other risks.

Senior management regularly discusses cyber risks and trends and, should they arise,

any material incidents with the Board of Directors.

Our business strategy, results of operations and

financial condition have not been materially affected by risks from cybersecurity threats, including as a result of previously identified

cybersecurity incidents, but we cannot provide assurance that they will not be materially affected in the future by such risks or any

future material incidents.

For more information on our cybersecurity related risks, see Item 1A Risk Factors of this Annual Report on

maintain a comprehensive process for identifying , assessing, and managing material risks from cybersecurity threats as part of our broader

risk management system and processes.

We closely follow the security industry and global threat trends, and our dedicated privacy, safety,

and security professionals oversee cybersecurity risk management and mitigation, incident prevention, detection, and remediation.

team and external partners include professionals with deep cybersecurity expertise across multiple industries, including our IT, Information

security & Quality Manager who oversees our cybersecurity operations.

Our executive leadership team, along with input from the above

professionals, are responsible for our overall enterprise risk management process and regularly consider cybersecurity risks in the context

of other material risks to the Company.

part of our cybersecurity risk management system, we track and log privacy and security incidents across Neonode, our vendors, and other

third-party service providers to remediate and resolve any such incidents.

Significant incidents are reviewed regularly by a cross-functional

team to determine whether further escalation is appropriate.

Any incident assessed as potentially being or potentially becoming material

is immediately escalated for further assessment, and then reported to designated members of our senior management .

We consult with outside

counsel as appropriate, including on materiality analysis and disclosure matters, and our senior management makes the final materiality

determinations and disclosure and other compliance decisions.

Board of Directors has oversight responsibility for risks and incidents relating to cybersecurity threats, including compliance with

disclosure requirements, cooperation with law enforcement, and related effects on financial and other risks.

Senior management regularly

discusses cyber risks and trends and, should they arise, any material incidents with the Board of Directors.

business strategy, results of operations and financial condition have not been materially affected by risks from cybersecurity threats,

including as a result of previously identified cybersecurity incidents, but we cannot provide assurance that they will not be materially

affected in the future by such risks or any future material incidents.

For more information on our cybersecurity related risks, see Item

1A Risk Factors of this Annual Report on Form 10-K.

of December 31, 2024, we leased office facilities of approximately 6,700 square feet for our corporate headquarter in Stockholm.

believe our facilities are adequate and suitable for our current needs and that suitable additional or alternative space will be available

to accommodate our operations if needed.

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