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 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 Exchange Act Rules 13a-15(e) and 15d-15(e)) as of April 30, 2021, 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, 2020, 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 April 30, 2021
that has materially affected, or is reasonably likely to materially affect, the Company’s internal control over financial reporting.
32
Part II – OTHER INFORMATION
Item 1. Legal Proceedings.
None.
Item 1A. Risk Factors.
As a “ smaller reporting company ” we are
not required to disclose information under this Item .
Text extracted from the filing as submitted to EDGAR. Formatting, tables and exhibits are simplified for reading; the original document is authoritative for anything you rely on.