Item 1B. Unresolved Staff Comments
Item 1B. Unresolved Staff Comments.
Not applicable.
Item 1C. Cybersecurity.
We use, store and process
data for and about our customers, employees, partners and suppliers. We have not yet implemented a formal cybersecurity risk management
program designed to identify, assess and mitigate risks from cybersecurity threats to this data, our systems and business operations.
We intend to implement a cybersecurity risk management program before the end of 2025.
Cyber Risk Management and Strategy
Under the oversight of the
Board of Directors (since we do not currently have an Audit Committee), we intend to implement and maintain a risk management program
that includes processes for the systematic identification, assessment, management, and treatment of cybersecurity risks. Our cybersecurity
oversight and operational processes would be integrated into our overall risk management processes. We intend to implement a risk-based
approach to the management of cyber threats, supported by cybersecurity technologies, including automated tools, designed to monitor,
identify and address cybersecurity risks. In support of this approach, it is expected that we would have a third-party security consultant
implement processes to assess, identify and manage security risks to our company, including in the pillar areas of security and compliance,
application security, infrastructure security and data privacy. This process, once implemented, would include regular compliance and critical
system access reviews. In addition, we intend to conduct application security assessments, vulnerability management, penetration testing,
security audits and ongoing risk assessments as part of our risk management process.
We expect to utilize third
parties and consultants to assist in the identification and assessment of risks, including to support tabletop exercises and to conduct
security testing. We intend to utilize well-known cloud-based technologies and service providers, such as Amazon AWS, Microsoft Office
and Google enterprise to provide protection against cybersecurity threats.
Further, we intend to put
processes in place that would evaluate potential risks from cybersecurity threats associated with our use of third-party service providers
that would have access to our data, including a review process for such providers’ cybersecurity practices, risk assessments, contractual
requirement and system monitoring.
Part of our intended program
would be ongoing evaluation and enhancement of our systems, controls and processes where possible, including in response to actual or
perceived threats specific to us or experienced by other companies.
Risks from cybersecurity threats
have, to date, not materially affected us, our business strategy, results of operations or financial condition.
Item 2. Properties.
Currently, we own no property.
Our principal executive office is located at 51st Floor, T1 Building, Qianhai Excellence No. 1, Shenzen, China. This office is provided
by sole director and officer, Jiang Jian, at no charge. We believe this office is adequate for our current operations.
Item 3. Legal Proceedings.
We are not currently a party to any legal proceedings,
and we are not aware of any pending or potential legal actions.
Item 4. Mine Safety Disclosures.
Not Applicable.
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PART II
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