What changed in this filing

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Item 4. Controls and Procedures

2021-02-16 compared with 2020-08-14 · 38 added, 20 removed, 7 unchanged (89% of the section changed)

CONTROLS AND PROCEDURES

of disclosure controls and procedures.

on an evaluation of our disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) of the Securities Exchange

Act of 1934, as amended) required by paragraph (b) of Rule 13a-15 or Rule 15d-15, as of June 30, 2020, our Principal Executive

Officer and Chief Financial Officer have concluded that, due to the material weaknesses in our internal control over financial

reporting, our disclosure controls and procedures were not effective.

We are committed to the remediation of the material weaknesses

described in our Annual Report on Form 10-K, as well as the continued improvement of our internal control over financial reporting.

We are in the process of taking steps to remediate the identified material weaknesses and continue to evaluate our internal controls

over financial reporting, including utilizing the services of external consultants for non-routine and\or technical accounting

issues as they arise.

As we continue our evaluation and improve our internal control over financial reporting, management may

identify and take additional measures to address control deficiencies.

We cannot assure you that we will be successful in remediating

the material weaknesses in a timely manner.

report includes the certifications of our Chief Executive Officer and Chief Financial Officer required by Rule 13a-14 of the Securities

Exchange Act of 1934 (the “Exchange Act”).

See Exhibits 31.1 and 31.2.

This Item 4 includes information concerning

the controls and control evaluations referred to in those certifications.

Controls and Procedures

required by Rule 13a-15(b) of the Exchange Act, we have evaluated, under the supervision and with the participation of our management,

including our principal executive officer and principal financial officer, the effectiveness of our disclosure controls and procedures

(as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act) as of the end of the period covered by this quarterly report.

Our disclosure controls and procedures are designed to provide reasonable assurance that the information required to be disclosed

by us in reports that we file under the Exchange Act is accumulated and communicated to our management, including our principal

executive officer and principal financial officer, as appropriate to allow timely decisions regarding required disclosure, and

is recorded, processed, summarized and reported within the time periods specified in the rules and forms of the SEC.

that evaluation, our principal executive officer and principal financial officer concluded that our disclosure controls and procedures

were effective as of the end of the period covered by this quarterly report, at the reasonable assurance level.

in Internal Control over Financial Reporting

required by Rule 13a-15(d) of the Exchange Act, our management, including our principal executive officer and our chief financial

officer, conducted an evaluation of the internal control over financial reporting to determine whether any changes occurred during

the quarter ended June 30, 2020 that have materially affected, or are reasonably likely to materially affect, our internal control

over financial reporting.

There have been no changes in our internal controls over financial reporting during the three months

ended June 30, 2020 that have materially affected, or are reasonably likely to materially affect, our internal control over financial

regularly review our system of internal control over financial reporting and make changes to our processes and systems to improve

controls and increase efficiency, while ensuring that we maintain an effective internal control environment.

Changes may include

such activities as implementing new, more efficient systems, consolidating activities and migrating processes.

were no significant changes in our system of internal control over financial reporting (as defined in Rule 13a-15(f) under the

Exchange Act) during the quarter ended December 31, 2020, that have materially affected, or are reasonably likely to materially

affect, our internal control over financial reporting.

Limitations on Internal Controls

should be noted that any system of controls, however well designed and operated, can provide only reasonable and not absolute

assurance that the objectives of the control system are met.

In addition, the design of any control system is based in part upon

certain assumptions about the likelihood of certain events.

Limitations inherent in any control system include the following:

in decision-making can be faulty, and control and process breakdowns can occur because of simple errors or mistakes;

can be circumvented by individuals, acting alone or in collusion with others, or by management override;

design of any system of controls is based in part on certain assumptions about the likelihood of future events, and there

can be no assurance that any design will succeed in achieving its stated goals under all potential future conditions;

time, controls may become inadequate because of changes in conditions or deterioration in the degree of compliance with associated

policies or procedures;

design of a control system must reflect the fact that resources are constrained, and the benefits of controls must be considered

relative to their costs.

of the inherent limitations in all control systems, no evaluation of controls can provide absolute assurance that all control

issues and instances of fraud, if any, have been detected.

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.

What changed 10-Q

Item 4. Controls and Procedures