Item 1B. Unresolved Staff Comments
ITEM
1B. UNRESOLVED STAFF COMMENTS
None.
ITEM
1C. CYBERSECURITY
We
acknowledge the increasing importance of cybersecurity in today’s digital and interconnected world. Cybersecurity threats pose
significant risks to the integrity of our systems and data, potentially impacting our business operations, financial condition and reputation.
As
a smaller reporting company, we currently do not have enhanced cybersecurity measures, a dedicated cybersecurity team or robust protocols
in place to manage cybersecurity risks. We have not yet conducted comprehensive risk assessments, established an incident response plan
or engaged with external cybersecurity consultants for assessments or services. We intend to invest more resources into improving our
assessment and response to cybersecurity risk in the future.
Given
our current stage of cybersecurity development, we have not experienced any significant cybersecurity incidents to date. However, we
recognize that the absence of a formalized cybersecurity framework may leave us vulnerable to cyberattacks, data breaches and other cybersecurity
incidents. Such events could potentially lead to unauthorized access to, or disclosure of, sensitive information, disrupt our business
operations, result in regulatory fines or litigation costs and negatively impact our reputation among customers and partners. In addition,
cybersecurity incidents could have material adverse effects on our business strategy, financial condition, and results of operations
(e.g., a significant breach could result in direct financial losses due to fraud, system downtime impacting revenue generation, increased
compliance costs or contractual liabilities with third-party vendors and customers).
We
are in the process of evaluating our cybersecurity needs and developing appropriate measures to enhance our cybersecurity posture. This
includes considering the engagement of external cybersecurity experts to advise on best practices, conducting vulnerability assessments
and developing an incident response strategy. Our goal is to establish a cybersecurity framework that is commensurate with our size,
complexity and the nature of our operations, thereby reducing our exposure to cybersecurity risks.
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In
addition, the Board will oversee any cybersecurity risk management framework, and the Board’s governance committee and the firm’s
CEO, Steven Rossi, will review and approve any cybersecurity policies, strategies and risk management practices .
The
Board (or designated committee or officer) will receive periodic updates on cybersecurity risks, including emerging threats, mitigation
efforts and incident response activities. The updates will be provided at least annually, or more frequently as needed, to ensure cybersecurity
risks are appropriately managed and integrated into our broader risk oversight strategy.
Despite
our efforts to improve our cybersecurity measures, there can be no assurance that our initiatives will fully mitigate the risks posed
by cyber threats. The landscape of cybersecurity risks is constantly evolving, and we will continue to assess and update our cybersecurity
measures in response to emerging threats. We do, however, have cybersecurity insurance coverage in the aggregate amount of $1,000,000
per annual policy period, which covers damages from a range of potential cyber security issues including but not limited to property
damage, computer crime, privacy liability, privacy regulatory defense, cyber extortion, and post breach remediation.
For
a discussion of potential cybersecurity risks affecting us, please refer to the “Risk Factors” section.
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