Unresolved Staff Comments.
−Removed: Not applicable.
Cybersecurity.
−Removed: We use, store and process
−Removed: data for and about our customers, employees, partners and suppliers.
−Removed: We have not yet implemented a formal cybersecurity risk management
−Removed: program designed to identify, assess and mitigate risks from cybersecurity threats to this data, our systems and business operations.
+Added: use, store and process data for and about our customers, employees, partners and suppliers.
+Added: We have not yet implemented a
+Added: formal cybersecurity risk management program designed to identify, assess and mitigate risks from cybersecurity threats to this
+Added: data, our systems and business operations.
We intend to implement a cybersecurity risk management program before the end of
Cyber Risk Management and Strategy
−Removed: Under the oversight of the
−Removed: Board of Directors (since we do not currently have an Audit Committee), we intend to implement and maintain a risk management program
−Removed: that includes processes for the systematic identification, assessment, management, and treatment of cybersecurity risks.
−Removed: Our cybersecurity
−Removed: oversight and operational processes would be integrated into our overall risk management processes.
−Removed: We intend to implement a risk-based
−Removed: approach to the management of cyber threats, supported by cybersecurity technologies, including automated tools, designed to monitor,
−Removed: identify and address cybersecurity risks.
−Removed: In support of this approach, it is expected that we would have a third-party security consultant
−Removed: implement processes to assess, identify and manage security risks to our company, including in the pillar areas of security and compliance,
−Removed: application security, infrastructure security and data privacy.
−Removed: This process, once implemented, would include regular compliance and critical
−Removed: system access reviews.
−Removed: In addition, we intend to conduct application security assessments, vulnerability management, penetration testing,
−Removed: security audits and ongoing risk assessments as part of our risk management process.
−Removed: We expect to utilize third
−Removed: parties and consultants to assist in the identification and assessment of risks, including to support tabletop exercises and to conduct
−Removed: security testing.
−Removed: We intend to utilize well-known cloud-based technologies and service providers, such as Amazon AWS, Microsoft Office
−Removed: and Google enterprise to provide protection against cybersecurity threats.
−Removed: Further, we intend to put
−Removed: processes in place that would evaluate potential risks from cybersecurity threats associated with our use of third-party service providers
−Removed: that would have access to our data, including a review process for such providers’ cybersecurity practices, risk assessments, contractual
−Removed: requirement and system monitoring.
−Removed: Part of our intended program
−Removed: would be ongoing evaluation and enhancement of our systems, controls and processes where possible, including in response to actual or
−Removed: perceived threats specific to us or experienced by other companies.
−Removed: Risks from cybersecurity threats
−Removed: have, to date, not materially affected us, our business strategy, results of operations or financial condition.
+Added: Under the oversight of the Board of Directors
+Added: (since we do not currently have an Audit Committee), we intend to implement and maintain a risk management program that includes processes
+Added: for the systematic identification, assessment, management, and treatment of cybersecurity risks.
+Added: Our cybersecurity oversight and
+Added: operational processes would be integrated into our overall risk management processes.
+Added: We intend to implement a risk-based approach to
+Added: the management of cyber threats, supported by cybersecurity technologies, including automated tools, designed to monitor, identify and
+Added: address cybersecurity risks.
+Added: In support of this approach, it is expected that we would have a third-party security consultant implement
+Added: processes to assess, identify and manage security risks to our company, including in the pillar areas of security and compliance, application
+Added: security, infrastructure security and data privacy.
+Added: This process, once implemented, would include regular compliance and critical system
+Added: access reviews.
+Added: In addition, we intend to conduct application security assessments, vulnerability management, penetration testing, security
+Added: audits and ongoing risk assessments as part of our risk management process.
+Added: We expect to utilize third parties
+Added: and consultants to assist in the identification and assessment of risks, including to support tabletop exercises and to conduct security
+Added: We intend to utilize well-known cloud-based technologies and service providers, such as Amazon AWS, Microsoft Office and Google
+Added: enterprise to provide protection against cybersecurity threats.
+Added: Further, we intend to put processes in place that
+Added: would evaluate potential risks from cybersecurity threats associated with our use of third-party service providers that would have access
+Added: to our data, including a review process for such providers’ cybersecurity practices, risk assessments, contractual requirement and
+Added: system monitoring.
+Added: Part of our intended program would be ongoing
+Added: evaluation and enhancement of our systems, controls and processes where possible, including in response to actual or perceived threats
+Added: specific to us or experienced by other companies.
+Added: Risks from cybersecurity threats have, to date,
+Added: not materially affected us, our business strategy, results of operations or financial condition.
Currently, we own no property.
−Removed: Our principal executive office is located at 51st Floor, T1 Building, Qianhai Excellence No.
−Removed: 1, Shenzen, China.
−Removed: This office is provided
−Removed: by sole director and officer, Jiang Jian, at no charge.
−Removed: We believe this office is adequate for our current operations.
+Added: Our mailed address
+Added: office is located at 1111 S.
+Added: Roop Street, #1915, Carson City, NV 89702 and is provided by sole director and officer, Richard Chiang at
+Added: We have been actively seeking new office space but have not been able to identify a suitable location.
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.