Unresolved Staff Comments
−Removed: our corporate headquarters we currently rent shared office space at 1120 Avenue of the Americas, 4 th Floor, New York, New
−Removed: York which can be 150 square feet.
−Removed: T he monthly services fee is $2,765.00 with a communications
−Removed: fee of $100 per month.
+Added: Not applicable.
+Added: Cybersecurity
+Added: We have processes for assessing, identifying,
+Added: and managing material risks from cybersecurity threats.
+Added: These processes are integrated into our overall risk management systems, as overseen
+Added: by our Board, primarily through its Audit Committee.
+Added: These processes also include overseeing and identifying risks from cybersecurity
+Added: threats associated with the use of third-party service providers.
+Added: We conduct risk assessments of certain third-party providers before
+Added: engagement and have established monitoring procedures in an effort to assess and mitigate potential data security exposures originating
+Added: from third parties.
+Added: We from time to time engages third-party consultants, legal advisors, and audit firms in evaluating and testing our
+Added: risk management systems and assessing and remediating certain potential cybersecurity incidents as appropriate.
+Added: Board of Directors
+Added: The Audit Committee of our Board oversees, among
+Added: other things, the adequacy and effectiveness of our internal controls, including internal controls designed to assess, identify, and manage
+Added: material risks from cybersecurity threats.
+Added: The Audit Committee is informed of material risks from cybersecurity threats pursuant to the
+Added: escalation criteria as set forth in our disclosure controls and procedures.
+Added: Further, our management team reports on cybersecurity matters,
+Added: including material risks and threats, to the Audit Committee.
+Added: Our management team also provides updates annually or more frequently as
+Added: appropriate to the full Board.
+Added: Under the oversight of the Audit Committee, and
+Added: as directed by our Chief Executive Officer, the Company’s Systems Application Manager, is primarily responsible for the assessment
+Added: and management of material cybersecurity risks and the Company’s annual security audits to meet the payment industry expectations.
+Added: Our management team holds a regular cybersecurity and business continuity reviews to evaluate data security exposures, control effectiveness
+Added: and necessary remediation actions.
+Added: The Systems Application Manager is also supported by a third-party information technology consulting
+Added: services provider who helps oversee our information technology systems and provides cross-functional support for cybersecurity risk management
+Added: and facilitates the response to any cybersecurity incidents.
+Added: Our Systems Application Manager oversees our cybersecurity
+Added: incident response plan and related processes that are designed to assess and manage material risks from cybersecurity threats.
+Added: Application Manager also coordinates with our legal counsel and third parties, such as consultants and legal advisors, to assess and manage
+Added: material risks from cybersecurity threats.
+Added: Our management team is informed about the effectiveness of the prevention, detection, mitigation,
+Added: and remediation of cybersecurity incidents pursuant to criteria set forth in our incident response plan and related processes.
+Added: Our Audit Committee is responsible for overseeing
+Added: the establishment and effectiveness of controls and other procedures, including controls and procedures related to the public disclosure
+Added: of material cybersecurity matters.
+Added: Our Systems Application Manager, or a delegate, informs the Chief Executive Officer of certain cybersecurity
+Added: incidents that may potentially be determined to be material pursuant to escalation criteria set forth in our incident response plan and
+Added: related processes.
+Added: The CEO also notifies the audit committee chair of any material cybersecurity incidents.
+Added: As of the date of this Report, we are not aware
+Added: of any cybersecurity incidents that have materially affected or are reasonably likely to materially affect the Company, including its
+Added: business strategy, results of operations, or financial condition and that are required to be reported in this Report.
+Added: For further discussion
+Added: of the risks associated with cybersecurity incidents, see the cybersecurity risk factor included in the section entitled “Item 1A.
+Added: Risk Factors” in this Report.
+Added: For our corporate headquarters we currently rent
+Added: shared office space at 1120 Avenue of the Americas, 4 th Floor, New York, New York which can be 150 square feet.
+Added: services fee is $2,765.00 with a communications fee of $100 per month.
Per the terms of the Agreement, the fees for the first and 13 th month
of the term (if extended beyond the initial term) shall be waived.
−Removed: The initial term of the Agreement is for one year, commencing September
−Removed: 1, 2022 and expiring August 31, 2023 with an automatic extension of the term of the Company does not provide at least 60 days prior notice
−Removed: to the end of the term.
−Removed: August 16, 2022, DMINT Real Estate Holdings, Inc.
−Removed: (“DREH”), a wholly owned subsidiary of purchased 4.73 acres of land and
−Removed: a building located at 565 Industrial Park Drive, Selmer, McNairy County, Tennessee for a purchase price of $408,000.00.
−Removed: DMINT established
−Removed: a Bitcoin mining data center powered on the local power grid.
+Added: The initial term of the Agreement is for one year, commenced on September
+Added: 1, 2022 and on August 31, 2023 the term automatically extended on a month-to-month basis and will continue to automatically extend monthly
+Added: if the Company does not provide at least 60 days prior notice.
+Added: On August 16, 2022, DMINT Real Estate Holdings,
+Added: (“DREH”), a wholly owned subsidiary of purchased 4.73 acres of land and a building located at 565 Industrial Park Drive,
+Added: Selmer, McNairy County, Tennessee for a purchase price of $408,000.00.
+Added: DMINT established a Bitcoin mining data center powered on the local
The location is expected to have capacity for up to 5,000 mining machines.
−Removed: rents approximately 4,277 square feet of property located at 960 Northpoint Parkway, Alpharetta, Georgia, Suite 400.
−Removed: The term of the
−Removed: Lease is for thirty-nine (39) months commencing September 1, 2020.
−Removed: The monthly base rent is $8,019 for the first twelve (12) months
−Removed: increasing thereafter to $8,768.
−Removed: The total rent for the entire lease term is $315,044 and $8,768 is payable as a security deposit.
−Removed: first three months of rent was abated.
−Removed: DMINT has two leases (the “Leases”) in Bradford, Pennsylvania
−Removed: relating to a combined 10,000 square feet of property located at the Bradford Regional Airport Authority multi-tenant building in Lafayette
−Removed: The Leases are each for a term of five years, ending on the later of the date of occupancy and November 10, 2026.
−Removed: base rent for “Cell 3”, comprising 4,000 square feet, is $1,666.67 per month.
−Removed: The monthly base rent for “Cell 4”,
−Removed: comprising 6,000 square feet, is $2,500 per month.
−Removed: The total rent for the entire lease term of the Leases is $250,000 and $8,767.85 is
−Removed: payable as a security deposit.
−Removed: DMINT is currently finalizing negotiations of an early termination of the Leases as it has moved all operating
−Removed: Bitcoin mining computers to its Selmer, TN location.
−Removed: Company also leases approximately 778 square feet at 3301 North Third, Abilene, Taylor County, Texas at $740 per month.
−Removed: a month-to-month rental which can be terminated at any time.
+Added: rents approximately 4,277 square
+Added: feet of property located at 960 Northpoint Parkway, Alpharetta, Georgia, Suite 400.
+Added: The term of the Lease is for thirty-nine (39) months
+Added: commencing September 1, 2020.
+Added: The monthly base rent is $8,019 for the first twelve (12) months increasing thereafter to $8,768.
+Added: total rent for the entire lease term is $315,044 and $8,768 is payable as a security deposit.
+Added: The first three months of rent was abated.
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.