What changed in this filing

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Item 4. Controls and Procedures

2022-03-16 compared with 2021-09-14 · 30 added, 21 removed, 4 unchanged (93% of the section changed)

Controls and Procedures.

of Disclosure Controls and Procedures

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 ”).

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 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

1 unchanged sentence

required disclosures.

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 July 31, 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.

in Internal Controls over Financial Reporting

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, 2021 that has materially affected, or is reasonably likely to materially affect, the Company’s

internal control over financial reporting.

II – OTHER INFORMATION

Our Chief Executive Officer (our principal executive

officer) and our Chief Financial Officer (our 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 January 31, 2022, 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, 2021, 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 January 31, 2022

that has materially affected, or is reasonably likely to materially affect, the Company’s internal control over financial reporting.

Part II – OTHER INFORMATION

Legal Proceedings.

In addition to matters previously

reported in our periodic filings under the Exchange Act, from time to time, we may become involved in various lawsuits and legal proceedings

which arise in the ordinary course of business.

Litigation is subject to inherent uncertainties, and an adverse result in any such matter

may harm our business.

Risk Factors.

a “ smaller reporting company ” we are not required to disclose information under

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-Q

Item 4. Controls and Procedures