UNRESOLVED STAFF COMMENTS
−Removed: This disclosure is not required as the Company is not an accelerated filer, large accelerated filer, nor a well-known
−Removed: seasoned issuer.
CYBERSECURITY
11 unchanged sentences
the complexity and evolving nature of cybersecurity threats, SideChannel, Inc.
−Removed: engages with a range of external experts, including cybersecurity
−Removed: assessors, consultants, and auditors in evaluating and testing our risk management systems.
−Removed: These partnerships enable us to leverage
−Removed: specialized knowledge and insights, ensuring our cybersecurity strategies and processes remain at the forefront of industry best practices.
−Removed: Our collaboration with these third-parties includes regular audits, threat assessments, and consultation on security enhancements.
+Added: has relationships with a range of external experts,
+Added: including cybersecurity assessors, consultants, and auditors in evaluating and testing our risk management systems.
+Added: partnerships enable us to leverage specialized knowledge and insights as needed, to ensure our cybersecurity strategies and
+Added: processes remain at the forefront of industry best practices.
+Added: Our collaboration with these third-parties may include audits, threat assessments, and consultation on security enhancements.
Third-party Risk
19 unchanged sentences
Role Managing Risk
−Removed: CISO and the Chief Executive Officer (“CEO”) play a pivotal role in informing the Audit Committee on cybersecurity risks.
+Added: The Chief Information Security Officer (“CISO”) and the Chief Executive Officer (“CEO”) play a pivotal role in informing the Audit Committee on cybersecurity risks.
They provide comprehensive briefings to the Audit Committee on a regular basis, with a minimum frequency of once per year.
39 unchanged sentences
to Board of Directors
−Removed: CISO, in his capacity, regularly informs the Chief Financial Officer (CFO) and Chief Executive Officer (CEO) of all aspects related to
−Removed: cybersecurity risks and incidents.
−Removed: This ensures that the highest levels of management are kept abreast of the cybersecurity posture and
−Removed: potential risks facing SideChannel, Inc.
−Removed: Furthermore, significant cybersecurity matters, and strategic risk management decisions are
−Removed: escalated to the Board of Directors, ensuring that they have comprehensive oversight and can provide guidance on critical cybersecurity
+Added: CISO, in his capacity, regularly informs the CEO and the Chief Financial Officer (“CFO”) of all
+Added: aspects related to cybersecurity risks and incidents.
+Added: This ensures that the highest levels of management are kept abreast of the
+Added: cybersecurity posture and potential risks facing SideChannel, Inc.
+Added: Furthermore, significant cybersecurity matters, and strategic
+Added: risk management decisions are escalated to the Board of Directors, ensuring that they have comprehensive oversight and can provide
+Added: guidance on critical cybersecurity issues.
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.