1 unchanged sentence
Evaluation of Disclosure Controls and Procedures
−Removed: Under the supervision and with the participation of our management, including our Chief Executive Officer and Chief Financial Officer, we have evaluated the effectiveness of our disclosure controls and procedures, as such term is defined under Rule 13a-15(e)
−Removed: promulgated under the Exchange Act, as of September 30, 2020.
−Removed: Based on that evaluation, our Chief Executive Officer and Chief Financial Officer have concluded that as of September 30, 2020, our disclosure controls and procedures were not effective due to a material weakness identified in our internal control over financial reporting as described below under “Management’s Report on Internal Control over Financial Reporting”.
−Removed: Management’s Report on Internal Control over Financial Reporting
−Removed: Our management is responsible for establishing and maintaining adequate internal control over financial reporting for us.
−Removed: Internal control over financial reporting (as defined in Rule 13a-15(f)
−Removed: of the Exchange Act) is a process to provide reasonable assurance regarding the reliability of our financial reporting for external purposes in accordance with accounting principles generally accepted in the United States.
−Removed: Internal control over financial reporting includes maintaining records that in reasonable detail accurately and fairly reflect our transactions;
−Removed: providing reasonable assurance that transactions are recorded as necessary for preparation of our financial statements;
−Removed: providing reasonable assurance that receipts and expenditures of company assets are made in accordance with management authorization;
−Removed: and providing reasonable assurance that unauthorized acquisition, use or disposition of company assets that could have a material effect on our financial statements would be prevented or detected on a timely basis.
−Removed: Because of its inherent limitations, internal control over financial reporting is not intended to provide absolute assurance that a misstatement of our financial statements would be prevented or detected.
−Removed: As of December 31, 2019, Management conducted an evaluation of the effectiveness of our internal control over financial reporting based on the framework in Internal Control—Integrated Framework
−Removed: issued by the Committee of Sponsoring Organizations of the Treadway Commission in 2013.
−Removed: As previously disclosed under “Item 9A.
−Removed: Controls and Procedures” in our Annual Report on Form 10-K
−Removed: for our fiscal year ended December 31, 2019, we identified the following deficiency that existed as of December 31, 2019 which continued to exist at September 30, 2020.
−Removed: This deficiency represented a material weakness in our internal control over financial reporting.
−Removed: A material weakness is a control deficiency or a combination of control deficiencies that results in more than a remote likelihood that a material misstatement of the annual or interim financial statements will not be prevented or detected.
−Removed: As of December 31, 2019 and September 30, 2020, management identified a material weakness in the design and effectiveness of our internal control over financial reporting.
−Removed: We did not design and maintain effective controls relating to the monitoring and oversight of expensing third party clinical trial costs.
−Removed: Specifically, our internal controls were not designed effectively to provide reasonable assurance regarding the accurate and timely evaluation of the amount of third-party costs to record.
−Removed: Based on this evaluation, management concluded that our internal control over financial reporting was not effective at September 30, 2020 because of the material weakness described above.
−Removed: Despite the existence of the material weakness described above, our financial statements as of September 30, 2020, are presented fairly, in all material respects, in conformity with accounting principles generally accepted in the United States of America.
−Removed: We have implemented measures to remediate the control deficiency that constituted the above material weakness by implementing changes to our internal control over financial reporting.
−Removed: We have designed, implemented and tested measures to work towards remediating the underlying causes of the control deficiency that gave rise to the material weakness.
−Removed: In addition, we have provided in-house
−Removed: accounting personnel training to ensure that they have the relevant expertise related to the monitoring and oversight of expensing third party clinical trial costs.
−Removed: We will continue to monitor the effectiveness of these controls and will make any further changes management determines appropriate.
−Removed: Changes in Internal Controls over Financial Reporting
−Removed: Except for the material weakness and related remediation efforts discussed above, there were no other changes in our internal control over financial reporting (as defined in Rule 13a-15(f)
−Removed: of the Exchange Act) that occurred during the fiscal quarter ended September 30, 2020 that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
+Added: Our management, with the participation of our principal executive officer and principal financial officer, has evaluated the effectiveness of our disclosure controls and procedures (as defined in Rules 13a-15(e)
+Added: under the Securities Exchange Act of 1934, as amended, or the Exchange Act) as of March 31, 2021.
+Added: The term “disclosure controls and procedures,” as defined in Rules 13a-15(e) and 15d-15(e) under the Exchange Act, means controls and other procedures of a company that are designed to ensure that information required to be disclosed by the company in the reports that it files or submits under the Exchange Act is recorded, processed, summarized and reported, within the time periods specified in the Securities and Exchange Commission’s rules and forms.
+Added: Disclosure controls and procedures include, without limitation, controls and procedures designed to ensure that information required to be disclosed by a company in the reports that it files or submits under the Exchange Act is accumulated and communicated to the company’s management, including its principal executive and principal financial officers, or persons performing similar functions, as appropriate to allow timely decisions regarding required disclosure.
+Added: Our management recognizes that any controls and procedures, no matter how well designed and operated, can provide only reasonable assurance of achieving their objectives and our management necessarily applies its judgment in evaluating the cost-benefit relationship of possible controls and procedures.
+Added: Based on the evaluation of our disclosure controls and procedures as of March 31, 2021, our principal executive officer and principal financial officer concluded that, as of such date, our disclosure controls and procedures were effective at the reasonable assurance level.
+Added: Changes in Internal Control over Financial Reporting
+Added: There were no changes in our internal control over financial reporting during the quarter ended March 31, 2021 that have materially affected, or are reasonably likely to materially affect, our internal control over financial reporting.
Part II - Other Information
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.