What changed in this filing

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Item 4. Controls and Procedures

2021-12-10 compared with 2021-06-21 · 18 added, 22 removed, 22 unchanged (65% of the section changed)

1 unchanged sentence

Evaluation of Disclosure Controls and Procedures

Management, with the participation of the Company’s

Chief Executive Officer and Chief Accounting Officer, evaluated the effectiveness of our disclosure controls and procedures as of April

The term “disclosure controls and procedures,”

as defined in Rules 13a-15(e) and 15d-15(e) under the Securities

Exchange Act of 1934, as amended (the “Exchange Act”), means controls and other procedures of a company that are designed

Management, with the participation of the Company’s

Chief Executive Officer and Chief Accounting Officer, evaluated the effectiveness of our disclosure controls and procedures as of July

The term “disclosure controls and procedures,” as defined in Rules 13a-15(e) and 15d-15(e) under the Securities

Exchange Act of 1934, as amended (the “Exchange Act”), means controls and other procedures of a company that are designed

to ensure that information required to be disclosed by a company in the reports that it files or submits under the Exchange Act is recorded,

processed, summarized and reported, within the time periods specified in the SEC’s rules and forms.

Disclosure controls and procedures

include, without limitation, controls and procedures designed to ensure that information required to be disclosed by a company in the

reports that it files or submits under the Exchange Act is accumulated and communicated to the company’s management, including

its principal executive and principal financial officers, as appropriate to allow timely decisions regarding required disclosure.

reports that it files or submits under the Exchange Act is accumulated and communicated to the company’s management, including its

principal executive and principal financial officers, as appropriate to allow timely decisions regarding required disclosure.

recognizes that any controls and procedures, no matter how well designed and operated, can provide only reasonable assurance of achieving

their objectives.

Based on the evaluation of our disclosure controls and procedures as of April 30, 2021, our Chief Executive Officer

Based on the evaluation of our disclosure controls and procedures as of October 31, 2021, our Chief Executive Officer

and Chief Accounting Officer concluded that, as of such date, as a result of the material weaknesses in internal control over financial

reporting that are described below in Management’s Report on Internal Control Over Financial Reporting, our disclosure controls

and procedures were not effective.

reporting that are described below in Management's Report on Internal Control Over Financial Reporting, our disclosure controls and procedures

were not effective.

As previously reported in our Annual Report on

3 unchanged sentences

Inadequate Segregation

We have an inadequate number of personnel to properly implement segregation of duties control procedures.

We are committed to improving our internal control

over financial reporting and (1) will continue to use third-party specialists to address shortfalls in staffing and to assist us with

accounting and finance responsibilities;

(2) will increase the frequency of independent reconciliations of significant accounts, which

will mitigate the lack of segregation of duties until there are sufficient personnel;

and (3) may consider appointing additional outside

directors and audit committee members in the future.

We have an inadequate number of personnel to properly implement control procedures.

We are committed to improving the internal controls

and will (1) continue to use third party specialists to address shortfalls in staffing and to assist us with accounting and finance responsibilities,

(2) increase the frequency of independent reconciliations of significant accounts, which will mitigate the lack of segregation of duties

until there are sufficient personnel, and (3) may consider appointing additional outside directors and audit committee members in the

In light of the material weakness described above,

prior to the filing of this Form 10-Q for the period ended April 30, 2021, management determined that key quarterly controls were

performed timely and also performed additional procedures, including validating the completeness and accuracy of the underlying data

used to support the amounts reported in the quarterly financial statements.

prior to the filing of this Form 10-Q for the period ended October 31, 2021, management determined that key quarterly controls were

performed timely and also performed additional procedures, including validating the completeness and accuracy of the underlying data used

to support the amounts reported in the quarterly financial statements.

These control activities and additional procedures have allowed

7 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.

What changed 10-Q

Item 4. Controls and Procedures