What changed in this filing

/stocks — the workspaceLOADING

Item 1B. Unresolved Staff Comments

2024-04-01 compared with 2023-04-06 · 49 added, 11 removed, 1 unchanged (98% of the section changed)

UNRESOLVED STAFF COMMENTS

We currently maintain our executive offices at

14 Wall Street, 20 th Floor, New York, NY 10005.

The cost for the space is included in the up to $10,000 monthly fee that we

pay our sponsor for office space, administrative and support services.

We consider our current office space adequate for our current operations.

Legal Proceedings

To the knowledge of our management, there is no

material litigation, arbitration or governmental proceeding currently pending against us or any members of our management team in their

capacity as such.

Mine Safety Disclosures

Not applicable.

CYBERSECURITY

Risk management and strategy

We are in the process of implementing

various information security procedures designed to identify, assess and manage material risks from cybersecurity threats to our critical

computer networks, third party hosted services, communications systems, hardware and software, and our critical data, including intellectual

property, confidential information that is proprietary, strategic or competitive in nature.

Our Chief Information Officer,

Chief Executive Officer, Vice President of Human Resources and Vice President of Operations help identify, assess and manage the Company’s

cybersecurity threats and risks.

They will identify and assess risks from cybersecurity threats by monitoring and evaluating our threat

environment using various methods including, for example manual and automated tools, subscribing to reports and services that identify

cybersecurity threats, conducting scans of the threat environment, evaluating threats reported to us, internal and external audits, conducting

threat assessments for internal and external threats, third-party threat assessments and conducting vulnerability assessments to identify

vulnerabilities.

Depending on the environment,

we are in the process of implementing various technical, physical, and organizational measures, processes, standards and policies designed

to manage and mitigate material risks from cybersecurity threats to our Information Systems and Data, including, for example:

response plan, incident detection, vulnerability management policy, network security controls, access controls, physical controls, systems

monitoring, vendor risk management program, employee training, penetration testing, systems monitoring.

Our assessment and management

of material risks from cybersecurity threats will be integrated into the Company’s overall risk management processes.

our Information Security Management committee will evaluate material risks from cybersecurity threats against our overall business objectives

and reports to the audit committee of the board of directors, which evaluates our overall enterprise risk.

We use third-party service

providers to assist us from time to time to identify, assess, and manage material risks from cybersecurity threats, including for example

professional services firms, including legal counsel, cybersecurity consultants, cyber security software providers and penetration testing

We use third-party service

providers to perform a variety of functions throughout our business, such as application providers and hosting companies.

For a description of the risks

from cybersecurity threats that may materially affect the Company and how they may do so, see our risk factors under Part I.

Risk Factors in this Annual Report on Form 10-K, including “Any unauthorized access to or disclosure or theft of personal information

we gather, store or use could harm our reputation and subject us to claims or litigation.”

Our board of directors addresses

the Company’s cybersecurity risk management as part of its general oversight function.

The board of directors’ audit committee

is responsible for overseeing Company’s cybersecurity risk management processes, including oversight of mitigation of risks from

cybersecurity threats.

Our Vice President of Information

Technology is responsible for hiring appropriate personnel, helping to integrate cybersecurity risk considerations into the Company’s

overall risk management strategy, and communicating key priorities to relevant personnel.

The Chief Financial Officer is responsible

for approving budgets, helping prepare for cybersecurity incidents, approving cybersecurity processes, and reviewing security assessments

and other security-related reports.

Our cybersecurity incident

response Policy is being designed to escalate certain cybersecurity incidents to members of management depending on the circumstances.

The Company’s Chief Executive Officer and Chief Information officer work to help the Company mitigate and remediate cybersecurity

incidents of which they are notified.

In addition, the Company’s incident response Policy will include reporting to the audit committee

of the board of directors for certain cybersecurity incidents.

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-K

Item 1B. Unresolved Staff Comments