What changed in this filing

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Item 1B. Unresolved Staff Comments

2025-04-15 compared with 2024-04-09 · 37 added, 30 removed, 19 unchanged (78% of the section changed)

1 unchanged sentence

Cybersecurity

manages cybersecurity and data protection through a continuously evolving framework.

The framework allows us to identify, assess and

mitigate the risks we face, and assists us in establishing policies and safeguards to protect our systems and the information of those

Our cybersecurity program is managed by our Director Product Management, Head of Data.

The Audit Committee of the Board of

Directors has oversight of our cybersecurity program and is responsible for reviewing and assessing the Company’s cybersecurity

and data protection policies, procedures and resource commitment, including key risk areas and mitigation strategies.

As part of this

process, the Audit receives regular updates from the Director Product Management, Head of Data on critical issues related to our information

security risks, cybersecurity strategy, supplier risk and business continuity capabilities.

The Company’s framework includes an

incident management and response program that continuously monitors the Company’s information systems for vulnerabilities, threats

and incidents;

manages cybersecurity and data protection through a continuously evolving framework, as described in further detail below.

The framework

allows us to identify, assess and mitigate the risks we face, and assists us in establishing policies and safeguards to protect our systems

and the information of those we serve.

Our cybersecurity program is managed by James Wang, our Chief Technology Officer.

a degree in computer science from the University of Hawaii at Manoa and has 19 years of development experience focused on architecture

and security.

In his career, he has led initiatives for companies to attain SOC2 compliance and PCI compliance for their product solutions.

The Audit Committee of the Board of Directors has oversight of our cybersecurity program and is responsible for reviewing and assessing

the Company’s cybersecurity and data protection policies, procedures and resource commitment, including key risk areas and mitigation

As part of this process, the Audit Committee receives regular updates from the Chief Technology Officer on critical issues

related to our information security risks, cybersecurity strategy, supplier risk and business continuity capabilities .

The Company’s

framework includes an incident management and response program that continuously monitors the Company’s information systems for

vulnerabilities, threats and incidents;

manages and takes action to contain incidents that occur;

remediates vulnerabilities;

and communicates the details of

threats and incidents to management, including the Director Product Management, Head of Data, as deemed necessary or appropriate.

to the Company’s incident response plan, any incidents are to be reported to the Audit Committee, appropriate government agencies

and other authorities, as deemed necessary or appropriate, considering the actual or potential impact, significance and scope.

and communicates

the details of threats and incidents to management, including the Director Product Management, Head of Data, as deemed necessary or appropriate.

Pursuant to the Company’s incident response plan, any incidents are to be reported by the Chief Technology Officer to the Audit

Committee, appropriate government agencies and other authorities, as deemed necessary or appropriate, considering the actual or potential

impact, significance and scope.

The Company is no t aware of any cybersecurity incidents or threats that are reasonably likely to materially

affect its business strategy, results of operations, or financial condition.

employ an array of data security technologies, processes, and methods across our infrastructure to protect systems and sensitive information

4 unchanged sentences

of security information and event management tools.

We developed, maintain and utilize a global integrated information security framework

We developed, maintained and utilized a global integrated information security framework

to guide our practices, based on relevant industry frameworks and laws, including, but not limited to NIST, GxP, HITRUST, the ISO 27000

7 unchanged sentences

We continuously monitor for threats and unauthorized access.

draw on the knowledge and insight of external cybersecurity experts and vendors, and internally employ dedicated, certified, cybersecurity

staff, such as but not limited to, CISSP, CISM, CISA, CSSP or other equivalent certifications, that leverage an array of third-party

tools to secure OneMedNet information infrastructure and protect systems and information from unauthorized access.

Non-technical safeguards

also play an important role in our cybersecurity program.

We provide various training programs and tools to employees so they can avoid

risky practices and help us promptly identify potential or actual issues.

We also have global incident response procedures, global service

tools to log incidents and issues for investigation, and an ethics line to report concerns and follow-up on matters already reported.

The Compliance team, led by our Chief Compliance Officer, develops and implements our strategy, as well as monitors systems and devices

for risks and threats.

corporate headquarters is in Eden Prairie, Minnesota is leased on a month-to-month basis.

draw on the knowledge and insight of external cybersecurity experts and vendors, and our Chief Technology Officer’s experience

in building solutions that are secure and compliant with our information security framework.

OneMedNet leverages an array of security

services and tools to secure OneMedNet information infrastructure and protect systems and information from unauthorized access.

products and solutions, including 3 rd party software and services such as hosted cloud based platforms are monitored by a

healthcare cloud, security and compliance organization that provides a real-time dashboard to monitor for potential threats and vulnerabilities.

Non-technical safeguards also play an important role in our cybersecurity program.

We provide various training programs and tools to

employees so they can avoid risky practices and help us promptly identify potential or actual issues.

We also have global incident response

procedures, global service tools to log incidents and issues for investigation, and an ethics line to report concerns and follow up on

matters already reported.

The Compliance team, led by our Chief Technology Officer, develops and implements our strategy, as well as

monitors systems and devices for risks and threats.

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