Unresolved Staff Comments.
−Removed: Not required for Smaller reporting companies.
+Added: Not applicable.
Cybersecurity.
−Removed: In 2024, we did not identify any cybersecurity
−Removed: threats that have materially affected or are reasonably likely to materially affect our business strategy, results of operations, or financial
−Removed: However, despite our efforts, we cannot eliminate all risks from cybersecurity threats, or provide assurances that we have
−Removed: not experienced undetected cybersecurity incidents.
−Removed: Currently we don’t own any properties.
−Removed: business office is located at Gieldowa 4A, Warsaw 01-211, Poland.
−Removed: This address was provided by sole officer and president, Wiktor Moroz.
−Removed: Our telephone number is +48222196622.
+Added: We use, store and process
+Added: data for and about our customers, employees, partners and suppliers.
+Added: We have not yet implemented a formal cybersecurity risk management
+Added: program designed to identify, assess and mitigate risks from cybersecurity threats to this data, our systems and business operations.
+Added: We intend to implement a cybersecurity risk management program before the end of 2025.
+Added: Cyber Risk Management and Strategy
+Added: Under the oversight of the
+Added: Board of Directors (since we do not currently have an Audit Committee), we intend to implement and maintain a risk management program
+Added: that includes processes for the systematic identification, assessment, management, and treatment of cybersecurity risks.
+Added: Our cybersecurity
+Added: oversight and operational processes would be integrated into our overall risk management processes.
+Added: We intend to implement a risk-based
+Added: approach to the management of cyber threats, supported by cybersecurity technologies, including automated tools, designed to monitor,
+Added: identify and address cybersecurity risks.
+Added: In support of this approach, it is expected that we would have a third-party security consultant
+Added: implement processes to assess, identify and manage security risks to our company, including in the pillar areas of security and compliance,
+Added: application security, infrastructure security and data privacy.
+Added: This process, once implemented, would include regular compliance and critical
+Added: system access reviews.
+Added: In addition, we intend to conduct application security assessments, vulnerability management, penetration testing,
+Added: security audits and ongoing risk assessments as part of our risk management process.
+Added: We expect to utilize third
+Added: parties and consultants to assist in the identification and assessment of risks, including to support tabletop exercises and to conduct
+Added: security testing.
+Added: We intend to utilize well-known cloud-based technologies and service providers, such as Amazon AWS, Microsoft Office
+Added: and Google enterprise to provide protection against cybersecurity threats.
+Added: Further, we intend to put
+Added: processes in place that would evaluate potential risks from cybersecurity threats associated with our use of third-party service providers
+Added: that would have access to our data, including a review process for such providers’ cybersecurity practices, risk assessments, contractual
+Added: requirement and system monitoring.
+Added: Part of our intended program
+Added: would be ongoing evaluation and enhancement of our systems, controls and processes where possible, including in response to actual or
+Added: perceived threats specific to us or experienced by other companies.
+Added: Risks from cybersecurity threats
+Added: have, to date, not materially affected us, our business strategy, results of operations or financial condition.
+Added: Currently, we own no property.
+Added: Our principal executive office is located at 51st Floor, T1 Building, Qianhai Excellence No.
+Added: 1, Shenzen, China.
+Added: This office is provided
+Added: by sole director and officer, Jiang Jian, at no charge.
+Added: We believe this office is adequate for our current operations.
Legal Proceedings.
4 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.