Item 4. Controls and Procedures
Item 4. Controls and Procedures.
Evaluation of Disclosure Controls and
Procedures
Disclosure controls are procedures that
are designed with the objective of ensuring that information required to be disclosed in our reports under the Securities Exchange
Act of 1934, as amended (the “Exchange Act”), such as this Quarterly Report, is recorded, processed, summarized and
reported in accordance with the rules of the United States Securities and Exchange Commission (the “SEC”). Disclosure
controls are also designed with the objective of ensuring that such information is accumulated appropriately and communicated to
management, including the chief executive officer and chief financial officer, as appropriate, to allow for timely decisions regarding
required disclosures.
Our Chief Executive Officer (principal
executive officer) and Chief Financial Officer (principal financial and accounting officer) evaluated the effectiveness of our
"disclosure controls and procedures" (as defined in the Securities Exchange Act of 1934 Rules 13a-15(e) and 15d-15(e))
as of July 31, 2020, the end of the period covered by this report. Based on that evaluation, our Chief Executive Officer and Chief
Financial Officer concluded that our disclosure controls and procedures were not effective as of such date to ensure that information
required to be disclosed by us in reports filed or submitted under the Exchange Act were recorded, processed, summarized, and reported
within the time periods specified in the SEC's rules and forms and that our disclosure controls are not effectively designed to
ensure that information required to be disclosed by us in the reports that we file or submit under the Exchange Act is accumulated
and communicated to management, including our principal executive officer and principal financial officer, or persons performing
similar functions, as appropriate to allow timely decisions regarding required disclosure. See the Company’s Annual Report
on Form 10-K for the fiscal year ended October 31, 2019, for a description of the Company’s material weaknesses in internal
control over financial reporting.
Changes in Internal Controls over Financial
Reporting
No change in our internal control over
financial reporting (as defined in Rules 13a-15(f) and 15d-15(f) under the Exchange Act) occurred during the fiscal quarter ended
July 31, 2020 that has materially affected, or is reasonably likely to materially affect, the Company’s internal control
over financial reporting.
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Part II – OTHER INFORMATION
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