What changed in this filing

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Item 1B. Unresolved Staff Comments

2024-03-25 compared with 2023-03-14 · 45 added, 10 removed, 6 unchanged (90% of the section changed)

Unresolved Staff Comments

Cybersecurity

board administers its cybersecurity risk oversight function directly through our audit committee.

Our audit committee has primary responsibility

for overseeing our risk assessment and risk management policies (including with respect to cybersecurity matters).

Our audit committee

regularly discusses with management, counsel, and auditors the Company’s major risk exposures.

This includes potential financial

impact on the Company and the steps taken to monitor and control those risks.

Additionally, our board is informed regarding the risks

facing the Company and coordinates with management and our cybersecurity team to ensure our board receives regular risk assessment updates

from management.

retain Techneto, Inc.

d/b/a CyberTeam (“CyberTeam”), a third party vendor that reports directly to our Chief Operating Officer,

to be responsible for identifying, assessing and managing the Company’s risks from cybersecurity threats.

CyberTeam has been with

the Company since its inception and has over 25 years of experience in cybersecurity.

provides our board and executive leadership team with periodic updates about our cybersecurity program and material risks.

This includes

updates on cybersecurity practices, programs, and the status of projects designed to strengthen internal cybersecurity and data protection.

Management and Strategy

for identifying and assessing cybersecurity risks

management, with the support of CyberTeam, monitors current events and trends related to cybersecurity and assesses any potential impact

on current systems and operations.

Third-party partners who are in possession of our confidential information are generally required

to notify us in the event of a cybersecurity incident within their systems that have, or are reasonably likely to, compromise the security

of such information.

When appropriate, we enlist CyberTeam to perform a risk and security assessment of the cybersecurity protocols and

procedures of critical third-party partners.

for managing cybersecurity risks

tracks risks and incidents related to cybersecurity until the risk is mitigated to an acceptable level or fully remediated.

are identified, CyberTeam oversees mitigation plans with the risk owner which are communicated to necessary teams and remediation steps

for incorporating cybersecurity risks into the overall risk management process

process for identifying, assessing, and managing risks related to cybersecurity generally involves CyberTeam regularly meeting with our

executive leadership team, and when appropriate, our board and/or audit committee to discuss cybersecurity related risks identified and

the potential likelihood and severity of each risk.

we are not aware of any risks from cybersecurity threats, or from previous cybersecurity incidents, that have materially affected or

are reasonably likely to materially affect the Company.

corporate offices are located at 360 Madison Avenue, 25th Floor, New York, NY 10017.

3 unchanged sentences

The Company or its subsidiaries also have entered into leases for a research and development facility

in Massachusetts with 7,375 square feet, which has a remaining term of 4.25 years, a CLIA laboratory in California with 21,019 square

feet, which has a remaining term of 2 years, and an office space in Pennsylvania with 4,300 square feet, which has a remaining

term of 4.8 years.

We also have lease agreements for our Lucid Test Centers in various locations in Arizona, California, Colorado,

Florida, Idaho, Illinois, Nevada, Ohio, Oregon, Texas and Utah that in the aggregate approximate 11,429 square feet.

this time, we consider our facility space to be commensurate with our current operations.

Notwithstanding, we may obtain additional space

in the future, as warranted by our business operations.

with the respective lease commencement dates, subsequent to December 31, 2022, the Company and its subsidiaries have entered into additional

lease agreements for additional Lucid Testing Centers with an aggregate of approximately 2,046 square feet.

in Massachusetts with 7,375 square feet, which has a remaining term expiring April 30, 2027, a CLIA laboratory in California with 21,019 square

feet, which has a remaining term expiring December 31, 2024, and an office space in Pennsylvania with 4,300 square feet, which has a remaining term expiring October 31, 2027.

We also have lease agreements for our Lucid Test Centers in various locations in Arizona, California, Colorado, Florida, Idaho,

Illinois, Nevada, Ohio, Oregon, Texas and Utah that in the aggregate approximate 15,048 square feet.

At this time, we consider our facility

space to be commensurate with our current operations.

Notwithstanding, we may obtain additional space in the future, as warranted by

our business operations.

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