What changed in this filing

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Item 4. Controls and Procedures

2020-08-10 compared with 2020-05-12 · 19 added, 25 removed, 15 unchanged (75% of the section changed)

1 unchanged sentence

of Disclosure Controls and Procedures

Under the supervision and with the participation

of our management, including our Chief Executive Officer and our Chief Financial Officer, we conducted an evaluation of our disclosure

controls and procedures, as such term is defined under Securities and Exchange Act of 1934 Rules 13a-15(f).

Based on this evaluation,

our Chief Executive Officer and our Chief Financial Officer concluded that the Company’s disclosure controls and procedures

were not effective as of March 31, 2020.

As of March 31, 2020, management’s assessment identified the following material

weaknesses in the Company’s internal control over financial reporting:

the supervision and with the participation of our management, including our Chief Executive Officer and our Chief Financial Officer,

we conducted an evaluation of our disclosure controls and procedures, as such term is defined under Securities and Exchange Act

of 1934 Rules 13a-15(f).

Based on this evaluation, our Chief Executive Officer and our Chief Financial Officer concluded that

the Company’s disclosure controls and procedures were not effective as of June 30, 2020.

As of June 30, 2020, management’s

assessment identified the following material weaknesses in the Company’s internal control over financial reporting:

IT Service Providers - The Company relies upon a variety of outsourced Information Technology (IT) service providers for key

4 unchanged sentences

and operation of internal controls pertaining to these outsourced IT service providers over the period of reliance.

management did not effectively assess the design and operation of certain outsourced IT service providers’

internal controls,

certain of the Company’s controls over IT systems and business processes were also ineffective, to the extent that they

rely upon information that was subject to the outsourced IT service providers’

control environment.

management did not effectively assess the design and operation of certain outsourced IT service providers’ internal controls,

certain of the Company’s controls over IT systems and business processes were also ineffective, to the extent that they

rely upon information that was subject to the outsourced IT service providers’ control environment.

of Duties - The Company did not maintain effective policies to ensure adequate segregation of duties within its accounting

2 unchanged sentences

in Internal Control Over Financial Reporting

have been no changes in the Company’s internal control over financial reporting during the three months ended March 31,

2020 that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial

Remediation Plans

As disclosed in the section titled “Risk

Factors”

in Part II, Item 1A of this Quarterly Report, we have begun, with the oversight of senior management and our audit

committee, to implement measures to remediate the identified material weakness.

The execution of our remediation is ongoing and

will require validation and testing of the design and operating effectiveness of internal controls over a sustained period of

financial reporting cycles.

Management expects to complete its remediation plan during the year ending December 31, 2020.

OTHER INFORMATION

have been no changes in the Company’s internal control over financial reporting during the three months ended June 30, 2020

that have materially affected, or are reasonably likely to materially affect, the Company’s internal control over financial

disclosed in the section titled “Risk Factors” in Part II, Item 1A of this Quarterly Report, we have begun, with the

oversight of senior management and our audit committee, to implement measures to remediate the identified material weakness.

execution of our remediation is ongoing and will require validation and testing of the design and operating effectiveness of internal

controls over a sustained period of financial reporting cycles.

Management expects to complete its remediation plan during the

year ending December 31, 2020.

II – OTHER INFORMATION

Legal Proceedings

2 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