reasoning: The paragraph describes the company's internal incident response planning and associated processes (triage, containment, remediation), which falls under Risk Management Process. It contains no named entities, specific dates, numbers, or unique program identifiers, consisting entirely of generic language applicable to any organization's incident response framework.


content_category: Management Role

category_confidence: high

specificity_confidence: high

reasoning: The paragraph focuses on the reporting structure and professional qualifications of specific management roles (CISO and VP of Platform and Technology Services), including career history and tenure date, which fits the Management Role category. It contains specific titles and a date (October 2012) that identify this as Paychex's specific disclosure, but lacks a second independently verifiable hard fact (like a specific headcount or dollar amount) needed for Quantified-Verifiable.

provider: moonshotai

stage: benchmark


content_category: Risk Management Process

reasoning: The paragraph describes the company's cybersecurity program, regulatory compliance approach, and adoption of industry frameworks to guide risk management activities. While it references the Board and executive management's commitment to resources, the central focus is on the internal program structure and processes rather than governance mechanisms or specific management roles.


content_category: Board Governance

reasoning: The paragraph describes Board and committee oversight of cybersecurity risk, including the CISO's reporting relationship to the Governance and Compliance Committee and the Technology Committee's role in reviewing product cybersecurity, with specific named committees and the CISO role.


reasoning: The paragraph describes the company's internal cybersecurity processes including detection, investigation, risk assessment, and incident response planning. While it briefly mentions that prior incidents did not have material adverse effects, the primary focus is on the company's risk management activities rather than a specific incident narrative or standalone materiality assessment. However, the disclosure contains no specific details, dates, named frameworks, or unique identifiers—it uses entirely generic language that could apply to any company.


content_category: Incident Disclosure

reasoning: The paragraph provides a detailed narrative of an actual cybersecurity incident from December 2022, describing the unauthorized extraction of employee personal data, containment protocols, and third-party expert engagement, which aligns with Incident Disclosure. The specific date provides a firm-specific fact, but the absence of named third-party firms, dollar amounts, or additional hard verifiable facts prevents it from reaching Quantified-Verifiable.


content_category: None/Other

reasoning: This is a SPAC (shell company) explicitly stating it lacks significant investments in data security protection and sufficient resources to protect against cyber incidents. Per the classification rules, SPACs explicitly stating they have no cybersecurity program or formal processes are classified as None/Other regardless of incidental mentions of board oversight.


reasoning: Paragraph describes internal risk management processes including threat intelligence, security tools, vulnerability management, and compliance activities. While the CISO is the grammatical subject initially, the content focuses on departmental functions and risk activities rather than personal qualifications or reporting structure. Contains firm-specific elements including the named internal department (CISS), cybersecurity-specific role (CISO), specific regulatory frameworks (NERC CIP, TSA Security Directives), and named industry coordination programs (E-ISAC, CRISP, Grid Security Exercises).


reasoning: The paragraph describes the company's internal cybersecurity risk management processes including risk identification, assessment, monitoring, and escalation procedures. While third-party oversight is mentioned, it is framed as a component of the company's internal risk management activities rather than the central topic. Specific facts include the named board member (Mr. Blattner) designated to receive reports and the specific departmental composition of the personnel overseeing third-party cyber risks.


content_category: Third-Party Risk

reasoning: The paragraph focuses entirely on vendor oversight and third-party risk management, describing requirements imposed on vendors (adherence to cybersecurity standards) and internal processes for rating vendor risks. This makes vendor oversight the central topic rather than a component of general risk management. However, the disclosure contains no named frameworks, specific dates, dollar amounts, headcounts, named third-party firms, or unique program identifiers—only generic descriptions of common practices like 'risk ratings' and 'data classification mapping' that could apply to any company.


reasoning: The paragraph describes an actual past cybersecurity incident with specific details including the year (2017), nature of the attack (criminal), and scope (theft of personal information affecting U.S., Canadian and U.K. consumers), which fits the Incident Disclosure definition. The specificity is Firm-Specific due to the specific date and geographic scope of the breach; it does not reach Quantified-Verifiable as it lacks a second hard verifiable fact such as dollar amounts, headcounts, or named third-party firms.


reasoning: This paragraph constitutes a pure cross-reference to Item 1A risk factor disclosures without stating a standalone materiality conclusion or describing specific governance structures, management roles, processes, or incidents. It merely directs readers to where discussions of material effects are located elsewhere in the filing, making it non-substantive for cybersecurity disclosure classification purposes.


reasoning: Paragraph focuses on the implementation and maintenance of cybersecurity processes and the Information Security program, describing the cross-functional organizational structure and specific departmental teams involved. While it mentions the CTO and CISO's experience, the emphasis is on the process and team composition rather than individual career qualifications.


reasoning: The paragraph describes the company's internal cybersecurity processes, including the incident response team structure, GRC platform, and third-party support services. While specific roles (CIO and Information Security Manager) are mentioned, the focus is on the functions and processes they perform rather than their personal qualifications, satisfying the Person-vs-Function test for Risk Management Process. It contains firm-specific details including cybersecurity-specific titles, a specific cross-functional team composition, and quantified experience (50 years), but lacks two hard verifiable facts (dates, dollar amounts, named third-party firms, or named products) required for Quantified-Verifiable.


reasoning: The paragraph describes the audit committee's oversight process (receiving briefings from management and reporting to the Board) where the board committee is the grammatical subject in the second sentence and the primary focus of the disclosure. It contains only generic elements: 'Chief Financial Officer' (standard C-suite), 'IT consultant' (vague/non-specific role), 'audit committee' (standard committee), and vague cadences ('periodic', 'regular') without specific dates, frameworks, or quantifiable details.


reasoning: The paragraph identifies specific cybersecurity management roles (interim CISO, CIO) and describes their reporting lines and participation in the ERC (Executive Risk Committee), a specific cross-functional executive forum. The grammatical subjects are the management roles and committee structure, fitting the Management Role category rather than Risk Management Process.


reasoning: The paragraph focuses on Board and Audit Committee oversight activities (reporting, receiving briefings, continuing education), with the Board/committee as the grammatical subject. While the CISO is mentioned, they appear only as a presenter to the Board rather than the primary subject. The disclosure identifies the specific cybersecurity role of CISO, which qualifies as firm-specific under the IS list, but lacks a second hard verifiable fact (date, dollar amount, headcount, percentage, or named third-party firm/tool) needed for Quantified-Verifiable.


reasoning: The paragraph provides a detailed narrative of an actual cybersecurity incident impacting third-party provider CDK, including specific dates of notification, system restoration, and transaction resumption (June 19, June 26, June 30, and July 31, 2024), the named vendor (CDK), affected systems (DMS, CRM), response actions, and operational impact on specific fiscal quarters.


reasoning: The paragraph focuses on the CIO and SIRT as the grammatical subjects, describing their specific cybersecurity expertise (security technologies, NIST/ISO/COBIT/ITIL standards, risk management) and their reporting relationship to the Audit Committee. While board oversight is mentioned, the emphasis is on management qualifications and activities, making Management Role the appropriate category. The identification of specific cybersecurity titles (CIO, SIRT) provides firm-specific details beyond generic boilerplate.


reasoning: Paragraph describes internal processes for threat assessment and incident response (notification protocols, mitigation actions) where management performs oversight functions. While 'management' is the grammatical subject, the content focuses on activities and processes rather than identifying specific cybersecurity roles (CISO/CIO/CTO) or their qualifications. Contains no specific facts, dates, dollar amounts, named frameworks, or organizational details—only generic governance terms ('management,' 'board of directors') applicable to any company.


reasoning: This paragraph contains only generic forward-looking risk disclosures and boilerplate language about potential cybersecurity threats and material adverse effects, with no substantive description of the company's actual cybersecurity governance, management, processes, or third-party oversight. As a SPAC with no operations, it provides no specific details about its cybersecurity program structure.


reasoning: The paragraph focuses on oversight by the Board of Directors' Technology Committee and ERM Committee, which are specific named committees serving as grammatical subjects that oversee the security team and receive regular updates on the program. It also contains two hard verifiable facts: the specific number 'over 50 years' combined experience and the named certification 'Certified Information Systems Security Professional' (CISSP).


reasoning: The board of directors is the grammatical subject describing the delegation of cybersecurity oversight to a subsidiary-level Information Security Committee and the briefing cadence to the board, fitting the Board Governance category.


reasoning: The paragraph focuses on identifying the specific management personnel (CFO, General Counsel, and Head of Information Technology) who lead cybersecurity efforts, their reporting structure, and their detailed professional qualifications and tenure, fitting the Management Role category. It includes firm-specific elements such as the cybersecurity-specific 'Head of Information Technology' title, the non-generic 'Information Technology Steering Committee,' and specific years of experience for each leader.


reasoning: The paragraph describes a specific cybersecurity incident involving stolen Bitcoin, detailing the threat actor's access method, forensic investigation, response actions (wiring funds, engaging a third-party firm, modifying controls), and quantified financial impact with a specific date. The presence of a specific date (June 30, 2023) and exact dollar amount ($560,000) provides two hard verifiable facts, meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity governance processes, including annual document reviews, a formal three-year strategic planning cycle, and progress reporting cadences. The Information Security team and CISO are discussed in functional terms (what they do) rather than as biographical profiles or board oversight mechanisms. Specific identifiers include the CISO title and the explicit 'three-year' plan duration, but no quantified metrics (dollar amounts, headcounts, specific dates) or named third-party vendors are present to reach Quantified-Verifiable.


specificity_confidence: medium

reasoning: Paragraph identifies specific management roles (IT Director and CFO) responsible for cybersecurity, including the IT Director's qualifications and reporting lines to the Board, fitting the Management Role category. While it mentions Board and Audit Committee oversight, the primary focus is on management structure and responsibilities. The disclosure is firm-specific because it identifies the specific organizational structure (IT Director as cyber lead reporting to CFO) rather than using generic boilerplate, but lacks quantifiable metrics or named third parties.


reasoning: The paragraph describes the company's internal process of engaging third-party service providers to perform cybersecurity functions (monitoring, vulnerability scanning, incident response, etc.) as part of its risk management infrastructure. It does not focus on vendor oversight or contractual requirements (which would be Third-Party Risk), nor does it name specific partners, frameworks, dates, dollar amounts, or tools—consisting entirely of generic service descriptions that could apply to any company.


reasoning: The paragraph focuses primarily on the CISO's qualifications (25+ years experience), appointment date (January 2025), and reporting structure (to CTO/CEO), fitting the Management Role category under the person-vs-function test. It meets the Quantified-Verifiable threshold with multiple specific dates (January 2025, October 2024, fiscal 2024) and a specific experience duration (over 25 years).


content_category: Strategy Integration

reasoning: This paragraph contains a standalone materiality assessment stating that no cybersecurity incidents have materially affected the company, which falls under Strategy Integration per the category tiebreakers. The language is standard boilerplate that could appear in any SEC filing without modification, containing no specific dates, amounts, or company-specific details.


reasoning: The paragraph identifies specific cybersecurity management roles (CIO and CISO) and details their responsibilities, reporting relationships, and oversight committees (InfoSec Steering Committee, InfoSec Governance Review Board, ERM Committee), which aligns with Management Role. It contains firm-specific organizational details including named committees and the Cyber Fusion Center, but lacks quantifiable metrics like specific dates, costs, or vendor names, resulting in Firm-Specific classification.


reasoning: Paragraph describes potential business and financial impacts of cybersecurity risks (revenue loss, regulatory fines, remediation costs, reputational damage) without referencing an actual incident, fitting Strategy Integration. The content uses conditional language ('could lead to,' 'could disrupt') and generic risk categories applicable to any company holding user data and intellectual property, with no specific dates, amounts, frameworks, or named entities.


reasoning: The paragraph focuses on Board oversight activities, with the Board of Directors as the grammatical subject receiving updates and discussing risk management strategies. It contains no specific facts, named committees (beyond the standard Board), specific roles (e.g., CISO), dates, or frameworks - only generic references to 'senior management' and standard oversight language that could apply to any company.


reasoning: The paragraph describes standard cybersecurity practices including third-party assessments, annual penetration testing, and vendor security reviews. While vendors are mentioned, they constitute only one component of the broader internal risk management process rather than the central topic. The disclosure lacks specific frameworks (e.g., NIST, ISO), dates, dollar amounts, named third-party firms, or cybersecurity-specific roles (e.g., CISO). References to 'Fortress IT Management' and 'infrastructure technology team' are functional descriptions that appear on the exclusion list (similar to generic 'management'), and 'annual' is explicitly listed as a generic cadence.


reasoning: The paragraph provides a detailed narrative of a specific business email compromise incident, describing the attack vector (impersonation of Sphere 3D's CFO), the scope of impact (26 BTC valued at ~$560,000), and response actions (engagement with US Federal law enforcement). It contains multiple hard verifiable facts including specific quantities, dollar amounts, and named entities (Sphere 3D, Gryphon).


reasoning: The paragraph describes the company's internal cybersecurity risk management processes and identifies the specific cross-functional teams (IT, Information Security, Product Security, Compliance, and Legal) responsible for oversight. This specific departmental composition constitutes a firm-specific organizational detail rather than generic boilerplate.


reasoning: The paragraph focuses on the CISO's reporting lines and communication responsibilities to board committees and senior management, fitting the Management Role category. It contains firm-specific elements including the cybersecurity-specific executive title (CISO) and a named non-generic committee (Technology Risk Management Committee), but lacks quantifiable data points like dates, headcounts, or dollar amounts needed for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes (risk assessment, incident detection, vulnerability management, etc.) and mentions third-party oversight as a component of these processes rather than as the central topic. It contains no named frameworks, specific dates, cybersecurity roles, third-party firms, or quantifiable details that would distinguish it from generic disclosure applicable to any company.


reasoning: The paragraph focuses on the CTO's qualifications (25 years of experience) and reporting structure, making the management role the grammatical subject. Per the person-vs-function test, the inclusion of career history/tenure details places this in Management Role rather than Risk Management Process.


reasoning: The paragraph describes the company's internal monitoring processes for cybersecurity incidents, fitting the Risk Management Process category. It contains no named tools, specific dates, dollar amounts, or other verifiable facts that would distinguish it from generic disclosure language applicable to any company.


reasoning: The paragraph focuses on Board and Committee oversight structures, with the FE Board, Audit Committee, and Operations and Safety Oversight Committee as the grammatical subjects describing their delegation of authority and oversight responsibilities. While the CISO is mentioned, the emphasis is on governance rather than management qualifications. Specific facts include the cybersecurity-specific CISO title, the non-generic Operations and Safety Oversight Committee (distinct from standard committees like Audit), and the specific year 2022, but only one hard verifiable fact (the year) is present, making this Firm-Specific rather than Quantified-Verifiable.


reasoning: The paragraph describes the management structure for cybersecurity operations, identifying the General Partner, Investment Manager, and reliance on Blackstone parent company personnel for assessing and managing cybersecurity risks, subject to Board oversight. While specific legal entity names are mentioned, these constitute company self-references or related parties that do not qualify as specific facts under the annotation guidelines; the paragraph contains no specific dates, quantified metrics, named third-party firms, cybersecurity-specific titles, or recognized frameworks.


reasoning: The paragraph describes the company's internal cybersecurity processes, controls, and third-party risk management procedures. While it identifies the CISO and CIO as overseers, the focus is on the functions and activities performed rather than the individuals' qualifications or backgrounds.


reasoning: The paragraph describes the company's enterprise risk management program and incident response processes, specifically outlining how cybersecurity risks and incidents are escalated from management to the board. While the COO and Audit Committee are mentioned, they are generic roles/committees per the exclusion list; however, the specific temporal reference 'beginning in 2024' provides a firm-specific detail that distinguishes this from generic boilerplate.


reasoning: The paragraph describes the audit committee's establishment and oversight through a cybersecurity sub-committee, with the committee/sub-committee as the grammatical subject. It identifies specific cybersecurity leadership titles (CIO and CISO) serving on the sub-committee, which qualifies as firm-specific content under the taxonomy.


reasoning: The paragraph provides a standalone materiality assessment stating that cybersecurity threats have not materially affected the company, without describing any specific incident or response actions. The cross-reference to Risk Factors does not change this classification. The language is standard boilerplate materiality disclaimer that could appear in any company's filing without modification.


reasoning: The Audit Committee is the grammatical subject receiving cybersecurity briefings, which constitutes board oversight of cyber risk. The paragraph contains only generic elements—standard 'Audit Committee,' vague 'quarterly' cadence, and broad topic categories—that could appear in any company's filing without modification.


reasoning: The paragraph focuses on the CISO and CRO as management personnel, describing their reporting lines to the risk committee and their escalation processes. Management roles are the primary grammatical subjects performing the actions (supporting oversight, providing reports, following escalation protocols). The identification of the CISO and the specific 'Risk Committee' (rather than just 'the Board' or 'Audit Committee') provides firm-specific detail.


reasoning: The paragraph describes the company's internal process for integrating cybersecurity risks into its enterprise risk management program and the annual review cycle, which falls under Risk Management Process. It contains no specific dates, named roles, frameworks, or unique organizational details—only generic references to 'the Board' and 'annually'—making it boilerplate language that could apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes, protocols, and policies (cross-departmental approach, software programs, policy review processes) rather than focusing on specific people or board oversight. However, it contains no firm-specific details: it lacks named frameworks, specific dates, dollar amounts, headcounts, named third-party firms, named security tools (only generic categories like 'antivirus protection'), or cybersecurity-specific roles (CISO/CTO/CIO), and references only the standard Audit Committee and generic departments.


reasoning: The paragraph describes specific response actions to an actual cybersecurity incident, including notification of approximately 1.3 million consumers and provision of credit monitoring services, as well as resulting litigation. While it includes a materiality assessment at the end, the primary focus is on the incident narrative, affected scope, and response activities rather than solely financial impact.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risks, with the Board as the grammatical subject receiving briefings from management. While the CTO is mentioned as providing presentations, the focus is on the Board's governance role and the Audit Committee's delegated monitoring responsibilities.


reasoning: The paragraph describes the company's internal cybersecurity processes including threat scanning, vulnerability assessments, incident detection, disaster recovery, and employee training. It contains no named frameworks, specific dates, dollar amounts, headcounts, named roles, or other firm-specific details that would distinguish it from a generic template applicable to any company.


reasoning: Paragraph describes the company's internal security governance structure and process for evaluating cyber risk. While it references a CFO and the Board, neither is the grammatical subject (the company 'we' is), and no qualifications, specific committees, or frameworks are named. Contains only generic C-suite titles and standard governance references that apply to any company.


reasoning: The paragraph describes the company's internal cybersecurity processes (risk assessment, security controls, and incident response planning) but references only a generic 'security team' without naming specific roles (e.g., CISO), frameworks, dates, or quantifiable details that would identify this as unique to Duke Robotics.


reasoning: The paragraph describes the company's internal cybersecurity processes including risk assessments, security controls, incident response, and employee training, but contains no specific identifying details such as named roles (e.g., CISO), frameworks, dates, headcounts, or third-party firms that would distinguish this disclosure from any other company.


reasoning: The paragraph's grammatical subject is the Technology and Operations Committee, describing its composition and oversight structure, which falls under committee governance. It identifies firm-specific elements including the named committee, cybersecurity-specific leadership roles (CIO, CISO), and specific departmental representations.


reasoning: The paragraph describes an actual email spoofing incident with specific dates (April 9, March 27, April 11, and April 12, 2024), the exact fraudulent wire transfer amount ($30,825), scope of affected payment, and detailed response actions including CISO reporting and implementation of new email verification controls.


reasoning: The paragraph identifies specific management roles (Executive Officer and Vice President of Technology) as the grammatical subjects providing cybersecurity briefings to the Board, describing the reporting line and communication structure. While 'Executive Officer' is generic C-suite, 'Vice President of Technology' is a cybersecurity-specific title that qualifies as a firm-specific fact.


reasoning: The paragraph's grammatical subject is the Risk and Compliance Oversight Committee (RCOC), a board committee responsible for overseeing the cybersecurity program and briefing the full Board, which clearly falls under Board Governance. The specificity is Firm-Specific because it identifies a uniquely named committee (RCOC) rather than generic governance terms like 'Audit Committee' or 'the Board'.


reasoning: The paragraph describes the company's internal cybersecurity processes including monitoring, system audits, and incident response planning. While the CISO and CIO are mentioned as grammatical subjects, the content focuses on their functional responsibilities (implementing and overseeing processes) rather than personal qualifications, credentials, or reporting structure, making Risk Management Process the appropriate category. The disclosure of CISO and CIO roles provides firm-specific detail.


reasoning: The paragraph focuses on identifying specific cybersecurity management positions (CTO, Information Security Manager/Officer) and their reporting relationships, and qualifies as Management Role under the person-vs-function test. It reaches Quantified-Verifiable specificity by providing two distinct numerical facts regarding the CTO's experience (30 years in IT and 20 years in cybersecurity) that are independently verifiable.


reasoning: The paragraph focuses on identifying the CISO and detailing specific qualifications (20 years experience, CISSP/CISM/GLAW/GSEC certifications, MBA) and reporting lines to the Chief Risk Officer, fitting the Management Role category. It contains multiple firm-specific facts including cybersecurity-specific titles, named non-generic committees (Risk Committee, Cybersecurity Committee), and specific professional credentials that identify this disclosure as unique to the company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including threat intelligence, intrusion detection, vulnerability management, and incident response protocols. While it mentions the CISO and Board, the grammatical focus is on the processes and systems ('multi-layered process', 'various processes', 'SOC provides'). It qualifies as Firm-Specific due to the identification of cybersecurity-specific organizational units (CISO, SOC, IRT) but lacks quantifiable data points (dates, dollar amounts, headcounts, named vendors) required for Quantified-Verifiable.


reasoning: The paragraph describes the company's internal process for evaluating and implementing safeguards to mitigate identified risks, which falls under Risk Management Process. While it mentions IT leadership reporting to the CEO, this is a generic structural detail rather than a specific cybersecurity role (e.g., CISO) with qualifications. The disclosure contains no named frameworks, specific dates, dollar amounts, headcounts, or other verifiable facts that would identify it as unique to this company.


reasoning: The paragraph contains a standalone materiality conclusion stating that cybersecurity incidents have not materially affected the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration. It contains no specific dates, dollar amounts, named roles, or other verifiable facts unique to the company, making it generic boilerplate language that could appear in any filing.


reasoning: The paragraph primarily addresses vendor oversight by describing requirements imposed on third-party service providers regarding security measures and breach reporting. The concluding sentence regarding Board and Audit Committee oversight is brief and secondary to the vendor evaluation process; moreover, the paragraph contains no specific facts, named entities, dates, or quantified details that would distinguish it from any other company's disclosure.


reasoning: Paragraph describes the company's internal cybersecurity processes including multi-layered defenses, insider threat monitoring, third-party risk assessments, and employee training as components of its overall risk management approach. No specific dates, dollar amounts, named vendors, frameworks, or unique program identifiers are disclosed; the content consists entirely of generic security practices and common governance activities applicable to any company.


reasoning: The paragraph describes a specific past cybersecurity incident (email spoofing) including the date (May 2014), attack method (scammer impersonating a subsidiary), target scope (customer payment), and response outcome (detected, no money sent), fitting the Incident Disclosure criteria. It contains one specific date (May 2014) but lacks a second hard verifiable fact (dollar amount, named firm, etc.) required for Quantified-Verifiable classification.


reasoning: The paragraph describes the company's Incident Response Plan (IRP) design, escalation procedures to the Audit Committee, and framework adoption, which are internal risk management processes. While it names the NIST Cybersecurity Framework, it lacks firm-specific details such as dates, headcounts, named tools, or unique program identifiers, making it Sector-Adapted.


reasoning: The paragraph describes internal processes for monitoring information systems, conducting audits, and maintaining incident response capabilities. While it mentions the InfoSec Director and eRISC, the focus is on the functions and activities performed (monitoring, deployment of measures, audits) rather than personal biographical details or board oversight. Specific firm identifiers include the cybersecurity-specific title 'InfoSec Director', the named internal entity 'eRISC', and reference to the specific industry organization 'FS-ISAC'.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks and their potential impact on business strategy, operations, and financial condition, without describing any specific incident or internal governance process. It contains only boilerplate materiality language and cross-references to Risk Factors, with no named entities, dates, dollar amounts, or specific identifying details.


reasoning: The paragraph describes management undergoing briefings to prepare for risk assessment, which constitutes an internal risk management process activity rather than a description of management qualifications (CFO is a generic C-suite role) or board governance. It contains no named entities, dates, numbers, or specific details—only generic references to a 'cybersecurity advisory firm' and 'third-party service providers'.


reasoning: The paragraph describes the company's internal incident response structure and workflows (crisis management team composition, Board communication protocols, and materiality evaluation processes), making it Risk Management Process. It contains cybersecurity-specific titles (CIO, CISO) and a specifically named committee (cyber incident disclosure committee), meeting the Firm-Specific threshold.


reasoning: The paragraph describes the company's internal cybersecurity processes (authentication, training, monitoring, encryption, vulnerability scanning) and mentions unnamed external service providers as a component of these processes, fitting Risk Management Process. It contains no named frameworks, specific dates, dollar amounts, headcounts, named tools, or named third-party firms—only generic program elements and standard security practices that could apply to any company.


reasoning: The paragraph describes the company's internal incident response procedures, cross-functional coordination protocols, and escalation processes. While it mentions an SVP Administration role, the focus is on what the Incident Response Committee and cross-functional teams DO (processes and activities), not on the person's qualifications or background. The disclosure includes firm-specific details: a named 'Incident Response Committee' and a specific departmental composition (technology, operations, legal, risk management) involved in the cross-functional approach.


reasoning: The paragraph describes the company's internal risk assessment activities and incident response planning, which are core components of cyber risk management processes. The language is entirely generic, citing standard practices (risk assessments, incident response plans) without naming specific frameworks, dates, tools, or roles unique to Cogent Communications.


reasoning: The paragraph contains a forward-looking materiality disclaimer ('could have a material adverse effect on us') and references cybersecurity insurance coverage, which falls under Strategy Integration per the tiebreaker rules. Despite the cross-reference to Risk Factors, the presence of a materiality assessment prevents classification as None/Other. The language is entirely generic with no named entities, specific coverage amounts, dates, or unique organizational details.


reasoning: The paragraph describes the Audit Committee's oversight role in reviewing IT systems and evaluating the information security program. As a standard board committee is the grammatical subject performing oversight functions, this fits Board Governance. However, the content contains only generic references (Audit Committee, management, information security program) with no specific frameworks, dates, roles, or organizational details, making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity management program, including processes for identifying and mitigating threats, quarterly review cadences, and benchmarking activities. It also notes the Audit Committee's role in receiving reports and evaluating risks as part of enterprise risk management. However, it contains no firm-specific details—no specific dates, cybersecurity-specific roles (e.g., CISO), named standards (only the vague reference to 'International Organization for Standardization' without specifying ISO 27001 or similar), or unique program identifiers. The Audit Committee is explicitly excluded as a specific fact per the guidelines, and 'quarterly' without exact dates is considered a generic cadence.


reasoning: The paragraph identifies specific cybersecurity management roles (ISO, CIO) and details their organizational structure, qualifications, and professional credentials (CISA certification, master's degrees), fitting the Management Role category. It contains firm-specific details including named cybersecurity-specific titles and quantified experience metrics, though only one hard verifiable fact (headcount of two) prevents Quantified-Verifiable classification.


reasoning: The paragraph identifies specific management positions (Senior Director of Information Technology and Senior Vice President, Quality Assurance) responsible for cybersecurity oversight and describes their team's qualifications and industry experience, fitting the Management Role category. It contains firm-specific details about the organizational structure and specific titles overseeing the program, but lacks quantifiable metrics or dates that would elevate it to Quantified-Verifiable.


reasoning: The paragraph describes a specific cybersecurity incident narrative, including forensic investigation completion and the last confirmed date of unauthorized activity. It contains two specific dates (December 13, 2023 and November 20, 2023) that satisfy the threshold for Quantified-Verifiable.


reasoning: The paragraph contains a standalone materiality conclusion stating that no material cybersecurity incidents were discovered in 2024, which per the guidelines classifies as Strategy Integration. The specific reference to the year 2024 provides one firm-specific fact, distinguishing it from generic boilerplate.


reasoning: The paragraph identifies specific cybersecurity leadership roles (chief security officer and chief privacy officer) and describes their qualifications (over 25 years of experience), making it about management roles rather than processes. It contains cybersecurity-specific titles and a numeric detail that distinguish it from generic boilerplate.


reasoning: The paragraph describes the company's internal processes for managing cybersecurity risk by engaging external firms for assessments and engineering support. It contains no named entities, specific dates, frameworks, or quantifiable details—only vague references to 'leading cybersecurity firms' and 'regular assessments' that could apply to any company.


reasoning: The paragraph describes a specific phishing attack incident with exact dates (April 28, 2023 and June 29, 2023), a specific monetary amount ($54,300), and details the response actions taken, fitting the Incident Disclosure category. The presence of two specific dates and a dollar amount provides multiple hard verifiable facts, making this Quantified-Verifiable.


reasoning: The paragraph describes internal risk management processes including a security points of contact program and a security council, rather than focusing on board oversight, individual management qualifications, or specific incidents. It contains firm-specific organizational details including the cybersecurity-specific CISO title, the named 'security council' committee, and the specific cross-functional composition of senior leaders from product development, operations, security, quality, and services.


reasoning: The paragraph describes the company's planned internal risk assessment activities as a component of its cybersecurity program, which falls under risk management processes. However, it contains only generic, high-level descriptions ('conducting risk assessments,' 'critical systems,' 'IT infrastructure') without naming specific frameworks, dates, roles, or quantifiable details that would distinguish Onconetix's approach from any other company.


reasoning: The paragraph is centrally focused on vendor oversight, describing the third-party service provider management program, contract review processes, and due diligence procedures for vendors. It qualifies as Firm-Specific because it identifies the specific organizational departments (Risk Management, Legal, and Information Security) involved in the oversight process, which is a concrete detail about internal structure not found in generic boilerplate.


reasoning: The paragraph describes oversight functions performed by the Cybersecurity Committee (a named board committee) and the CISO, with both serving as grammatical subjects performing governance activities. It contains firm-specific identifiers including the cybersecurity-specific title (Chief Information Security Officer) and a named non-generic committee (Cybersecurity Committee).


reasoning: The paragraph primarily describes the company's internal risk management structures, policies, and organizational placement of its cybersecurity function within the operations department. While it opens with a materiality disclaimer, the substantive content focuses on internal processes and organizational structure rather than board oversight, specific management roles, or financial strategy.


reasoning: The paragraph describes the company's internal cybersecurity risk management program, its integration with enterprise risk management, and specifically names the NIST Cybersecurity Framework as the guiding standard for risk identification and prioritization. It contains no firm-specific details such as dates, headcounts, named roles, or unique organizational structures.


reasoning: The paragraph describes internal risk assessment processes, safeguards, and reporting mechanisms (risk management activities), and would still make sense if the CISO title were removed, indicating it is about the function, not the person. The specific title 'Chief Information Security Officer' provides a firm-specific detail, while 'Audit Committee' and 'regular' briefings are generic governance elements.


reasoning: The paragraph's grammatical subject is the Chief Information Officer (CIO), describing the role's reporting line to the CEO, support structure, and the specific incumbent's extensive experience. This focuses on identifying a key cybersecurity management position and its qualifications rather than detailing internal processes or board oversight.


reasoning: The paragraph provides a standalone materiality assessment stating that no cybersecurity incidents during fiscal year 2023 had material impact on business operations or financial condition, which falls under Strategy Integration per the category rules. The specific fiscal year end date of December 31, 2023 qualifies as a firm-specific fact, distinguishing it from generic boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity risk management approach and incident response planning using generic language ('comprehensive, cross-functional approach', 'cybersecurity incident response plan') without identifying specific frameworks, named roles, dates, or organizational details unique to the firm.


reasoning: The paragraph focuses on the CIO's personal qualifications (15 years experience) and specific reporting structure rather than describing the risk management processes themselves, satisfying the person-vs-function test for Management Role. It contains a cybersecurity-specific title and specific tenure, making it Firm-Specific.


reasoning: Paragraph provides generic business context about the importance of IT systems and types of sensitive data handled (PHI, PII), but discloses no substantive information regarding cybersecurity governance structures, risk management processes, specific incidents, or financial/materiality assessments. References to HIPAA and CCPA are regulatory compliance mentions applicable to any healthcare company, not firm-specific disclosures.


category_confidence: medium

reasoning: The paragraph describes the company's general commitment to developing and maintaining cybersecurity measures, which aligns with risk management process disclosure, but contains only generic language about safeguarding information systems that could apply to any company without naming specific frameworks, roles, dates, or practices.


reasoning: The paragraph describes the company's internal risk management processes, specifically framework adoption (NIST Cybersecurity Framework 2.0, ISO 27001), certification maintenance, and audit procedures. It is Firm-Specific because it includes specific years (2022, 2025) when certification was achieved and surveillance audits conducted, plus the specific certification (ISO/IEC 27001:2022) held by the company.


reasoning: The paragraph identifies a specific cybersecurity leadership role (Director of Information Technology and Security) and provides detailed qualifications (40 years of experience), which aligns with the Management Role category. While it describes internal processes performed by the CSIRT, the emphasis on the specific director's credentials and leadership makes this a management-focused disclosure.


reasoning: This paragraph contains a standalone materiality conclusion stating that cybersecurity risks have not materially impacted operations or financial results to date, which falls under Strategy Integration per the guidelines. It contains no specific details about the company's cybersecurity program, governance structure, or risk management processes—only generic forward-looking disclaimers and a cross-reference to Risk Factors.


reasoning: Paragraph focuses on Board and Audit Committee oversight of cybersecurity risks, including briefing cadences (quarterly/annual) and incident escalation protocols. Contains cybersecurity-specific role (VP of Information Technology) and specific cross-functional team composition (legal, finance, corporate governance), but lacks quantifiable metrics or external verification points needed for Quantified-Verifiable.


reasoning: The paragraph establishes Board and committee oversight as the primary governance framework, beginning with the Board of Directors and Board Risk Committee's oversight role and concluding with the reporting cadence to these bodies. While specific management roles (CTO, Information Security Manager) are identified, they are framed within the context of operational execution under Board oversight rather than as a focus on individual qualifications or reporting lines.


reasoning: The paragraph describes internal processes for maintaining cybersecurity knowledge through training and certifications. It contains multiple named third-party organizations (FS-ISAC, American Bankers Association, Mid-Sized Banking Coalition of America) and numerous specific professional certifications (GIAC, CompTIA, ISC2, CERT), providing well over two hard verifiable facts.


reasoning: The paragraph centers on the COO's qualifications (specific tenure) and reporting responsibilities to the Board, making the management role the grammatical subject and primary focus. It contains one specific numerical fact (30 years) but lacks a second hard verifiable fact (such as a specific date, dollar amount, or named third-party firm) required for Quantified-Verifiable classification.


reasoning: The paragraph describes the company's internal processes for identifying and assessing cybersecurity risks (monitoring, threat analysis, vulnerability assessments, tabletop exercises). While it mentions specific management titles, the focus is on the functions and activities performed rather than the individuals' qualifications or backgrounds, satisfying the Person-vs-Function test for Risk Management Process. The inclusion of specific role titles ('Head of Global Information Technology' and 'Chief Compliance Officer') provides firm-specific detail beyond generic boilerplate.


reasoning: Paragraph describes internal processes (incident response planning, policy development, oversight meetings) rather than specific management personnel qualifications or board oversight. Contains no named frameworks, cybersecurity-specific titles (e.g., CISO), dates, dollar amounts, or named third-party firms—only generic references to 'senior executives' and 'an IT Managed Service Provider' that could apply to any company.


reasoning: The paragraph focuses on the qualifications, career history, and reporting structure of the CIO (a cybersecurity-specific management role) and describes the composition of the internal ISMS Committee, which is a management-level body rather than a Board committee. While it mentions risk assessment activities, the emphasis is on the people and governance structure (who oversees the program) rather than the process mechanics.


reasoning: The paragraph contains a standalone materiality assessment stating that cybersecurity risks have not had a material impact on operations, business strategy, or financial results, which falls under Strategy Integration per the tiebreaker rules. Despite referencing governance procedures described elsewhere, the substance is boilerplate forward-looking materiality language with no specific dates, dollar amounts, named roles, or other verifiable facts.


reasoning: Paragraph describes the company's internal policies and procedures for assessing, identifying, and managing cybersecurity risks, and their integration into the enterprise risk management program. This falls squarely under Risk Management Process. The disclosure contains no specific frameworks, dates, named roles, or unique program identifiers—only generic references to 'management,' 'Board of Directors,' and 'Audit Committee' (standard governance entities) and 'enterprise risk management program' (standard business term), making it Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes including technical safeguards, incident response planning, third-party risk management, and employee training. While it mentions third-party risk, this is one component of the broader risk management process rather than the central topic. Specificity is Firm-Specific due to the named 'Information Security and Privacy team' and the formal program identifier 'Third-Party Risk Management (TPRM)', though no quantifiable data or named external standards are provided.


reasoning: The paragraph identifies specific management positions (CTO, VP/GM, VP of Managed Services) and details the professional qualifications, career tenure (40 years, 20+ years), and educational credentials (Bachelor's and Master's degrees) of the individuals holding these roles. This focuses on the people rather than processes, satisfying the Person-vs-Function test for Management Role. The presence of two specific durations (40 years and over twenty years) and two named academic credentials provides multiple hard verifiable facts, meeting the Quantified-Verifiable threshold.


reasoning: Paragraph identifies the CTO and describes their membership in a dedicated cybersecurity committee alongside other senior executives (COO/CRO, CCO), establishing clear management oversight structure and reporting lines to the ERM committee.


reasoning: The paragraph focuses on Board and Audit Committee oversight of cybersecurity risk, with the Board as the grammatical subject of the first two sentences. It contains only generic governance terms (Board, Audit Committee, CFO, quarterly) without naming specific frameworks, dates, cybersecurity-specific roles, or firm-unique operational details.


reasoning: The paragraph focuses on the Audit Committee's oversight responsibilities, including its review of cybersecurity risks, receipt of annual risk assessments, and reporting to the Board. While it mentions the CISO and information security team, they appear as objects of the committee's oversight rather than the primary subject.


reasoning: The paragraph describes internal monitoring, detection, and escalation processes but does not name specific tools, frameworks, dates, or unique organizational structures. The mention of CSIRT analysts and escalation to the Board describes standard security operations center functions without firm-specific details.


reasoning: The paragraph describes the company's internal IT risk identification process and risk register, categorizing cybersecurity as a subcategory of IT risk. It contains no named frameworks, specific roles, dates, numbers, or firm-specific details that would distinguish it from a generic disclosure applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, specifically referencing the named internal program 'WISP' and assessments conducted against the NIST framework. The use of the specific program acronym 'WISP' and integration with the Internal Audit department provide firm-specific details that distinguish this disclosure from generic boilerplate language.


reasoning: The paragraph describes specific incident response actions, notification efforts to consumers and regulators, and the scope of a real cybersecurity incident affecting 1.3 million consumers, as well as related litigation. While it includes a materiality conclusion, the primary focus is on describing the incident's impact and response actions. The specific quantification of impacted consumers provides one hard verifiable fact, making it Firm-Specific rather than Quantified-Verifiable (which would require two or more hard facts such as dates, dollar amounts, or named third-party firms).


reasoning: The audit committee is the grammatical subject throughout, describing its oversight of cyber risks, briefing cadence ('at least annually'), and interactions with management and service providers. While it mentions AGM (a named entity) and CSO/CISO titles (cybersecurity-specific roles), it contains only one hard verifiable fact (AGM as a named third-party), making it Firm-Specific rather than Quantified-Verifiable.


reasoning: The Trust explicitly states it has no officers, directors, or employees and relies entirely on the Sponsor (BlackRock) for cybersecurity risk management, constituting a disclosure of the absence of a standalone program rather than a substantive description of internal governance, management, or processes. Per the guidelines, entities explicitly stating they have no formal processes or personnel are classified as None/Other regardless of incidental mentions of sponsor board oversight.


reasoning: The paragraph describes the company's internal incident response program, escalation protocols, and severity assessment procedures, which are core risk management processes. The mention of third-party providers is ancillary to describing the incident response capability rather than being the central topic of vendor oversight. The text contains no specific dates, named roles, named third-party firms, dollar amounts, or other identifying details—only generic references to 'designated personnel,' 'regularly tested' programs, and unnamed 'third-party service providers.'


reasoning: The paragraph provides a standalone materiality assessment stating that cybersecurity threats have not materially affected the company during 2024 and 2023, without describing any specific incident narrative. This is standard boilerplate disclaimer language that could appear in any company's filing.


reasoning: The paragraph describes the company's internal cybersecurity processes, including engaging external specialists for assessments, maintaining a multi-year strategic plan, and employing various defense mechanisms. While it mentions third-party cloud supplier assessments, this is framed as one component of the broader risk management program rather than the central topic. The specificity is Firm-Specific due to the mention of a '5-year plan' (a specific duration), though no named frameworks, roles, dates, or quantified metrics appear.


reasoning: The paragraph describes the company's internal department responsible for day-to-day cybersecurity risk management processes, control standards, and procedures, which falls under Risk Management Process. It identifies a specific 'Information Security Department' as the dedicated organizational unit, which constitutes a firm-specific fact, but lacks quantifiable details like headcounts, named certifications, or specific dates needed for Quantified-Verifiable.


reasoning: The paragraph primarily describes the company's internal risk management activities—vulnerability assessments, penetration testing, enterprise risk assessments, and integration with the broader ERM program—with the company ('we') as the grammatical subject. While the CISO is mentioned as overseeing the assessment and the final sentence notes the CISO's experience, the focus is on the function and processes rather than the person's qualifications or reporting structure. The disclosure contains a cybersecurity-specific title (CISO) and a specific number (20 years), meeting the Firm-Specific threshold, but lacks a second hard verifiable fact (date, dollar amount, named vendor/tool) needed for Quantified-Verifiable.


reasoning: The paragraph describes potential business impacts (operational disruption, production delays) of cybersecurity incidents, which falls under Strategy Integration's scope of business/financial impact. The language is entirely hypothetical and generic, containing no specific details about the company's operations, dates, or quantifiable risks, making it applicable to any company.


reasoning: The paragraph comprehensively describes the company's cybersecurity risk management processes, including internal controls, third-party service engagements, employee training, penetration testing, and continuous monitoring tools. While it identifies specific cybersecurity leadership titles (CIO and VP of IT Infrastructure Operations and Security) and mentions PCI attestation, the grammatical focus is on the department's functions and processes rather than the individuals' qualifications or reporting lines, satisfying the Person-vs-Function test for Risk Management Process.


reasoning: The paragraph describes a specific historical cybersecurity incident, including the date (2021), nature of the attack (ransomware by an external actor accessing data), and resulting litigation, which constitutes incident narrative. While it includes materiality language at the end, the primary substance is the description of what happened in the actual event.


reasoning: The paragraph describes Board and Audit Committee oversight of cybersecurity risks, with the Board/Committee as the grammatical subject receiving reports from management. It identifies specific cybersecurity leadership titles (CTO and CISO) that satisfy the Firm-Specific threshold, though it lacks quantified data or specific dates.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including ERM Committee integration, internal audit assessments, and ARB/PMO review procedures, rather than focusing on board oversight or individual management qualifications. It contains firm-specific details through the naming of specific committees (ERM Committee, ARB, PMO) and the CTO reporting structure.


reasoning: The paragraph describes the company's internal information security processes for identifying, assessing, and managing cybersecurity risks, fitting the Risk Management Process category. It contains no specific details, dates, named roles, frameworks, or quantifiable facts, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal cybersecurity programs, administrative safeguards, and risk management processes. It references the NIST Cybersecurity Framework but provides no firm-specific implementation details, certifications, or quantifiable metrics beyond naming this standard.


reasoning: The paragraph focuses on the Audit Committee's primary responsibility for overseeing cybersecurity risk and the CISO's direct reporting line to that committee. While the Audit Committee itself is a standard governance body, the identification of the CISO—a cybersecurity-specific title—provides a firm-specific detail that distinguishes this disclosure from generic boilerplate.


reasoning: The paragraph contains a standalone materiality disclaimer stating that cybersecurity risks have not materially affected operations, business strategy, or financial results, which falls under Strategy Integration per the tiebreaker rules. The text contains no specific dates, dollar amounts, named roles, frameworks, or other verifiable facts—only generic references to 'cybersecurity program' and 'Risk Factors' that could apply to any company.


reasoning: The paragraph describes the company's internal incident response workflow—how risks are identified, assessed, escalated, and resolved—making it a Risk Management Process disclosure. It identifies the 'VP of IT' as a specific cybersecurity role, which distinguishes it from generic boilerplate, though it lacks quantifiable details like dates, costs, or named vendors that would elevate it to Quantified-Verifiable.


reasoning: The paragraph provides a standalone materiality conclusion stating that no cybersecurity threats have materially affected the company, which per the tiebreaker rules maps to Strategy Integration. The language is standard boilerplate materiality disclaimer that could appear in any SEC filing, containing no specific dates, incidents, roles, or quantifiable details.


reasoning: The paragraph identifies the company's CISO as the grammatical subject and focuses on his qualifications (28 years experience, master's degree), specific certifications (CISA, CISM, HITRUST, QSA, CSP), and team structure (ISOs and third-party consultant), which falls under Management Role. It meets the Quantified-Verifiable threshold with multiple hard facts: specific headcount (28 years) and numerous named certifications.


reasoning: Paragraph describes the company's internal vulnerability management processes, including bug bounty programs and remediation tracking. While it mentions 'management' and the 'board of directors' as report recipients, the focus is on operational risk activities, not governance structure. No specific dates, dollar amounts, named frameworks (NIST/ISO), cybersecurity-specific roles (CISO/CIO), named tools, or third-party firms are identified—only generic descriptions of testing activities and reporting cadences.


reasoning: The paragraph describes the board's governance structure, specifically the management committees established by the board (IT Steering Committee and Operational Risk Management Committee), their composition, meeting cadences, and reporting lines to the board-level Innovation and Technology Committee. While management titles are mentioned, the focus is on oversight mechanisms and governance hierarchy rather than individual qualifications or operational processes.


reasoning: Paragraph contains a standalone materiality conclusion stating that threats have not resulted in a material cybersecurity incident to date, and discusses potential business/financial impacts and insurance coverage, fitting the Strategy Integration category. No specific dates, dollar amounts, named entities, or frameworks are provided, making it Generic Boilerplate.


reasoning: The paragraph constitutes a materiality disclaimer stating that cybersecurity incidents have not materially affected the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration per the tiebreaker rules. It contains no specific dates, dollar amounts, named third-party firms, or other verifiable facts—only generic language that could apply to any company.


reasoning: The paragraph describes the company's internal cyber risk management processes and governance framework, including the Global Security Organization's operational role, integration with the ERM program, and the specific IRM program managed by the IRM Steering Committee. While it mentions the CSO and the board-level Risk Committee, the focus is on the functional processes and organizational structure rather than individual qualifications or standalone board oversight.


reasoning: This paragraph provides a definitional overview referencing Item 106(a) of Regulation S-K and lists generic categories of cybersecurity risks (operational risks, IP theft, fraud, etc.) without disclosing any specific governance structures, management roles, internal processes, or firm-specific programs. It functions as introductory regulatory boilerplate rather than substantive disclosure of the company's cybersecurity program.


reasoning: The paragraph describes the board of directors receiving regular presentations on cybersecurity risks from senior management, which constitutes board oversight of cyber risk and briefing cadence. It contains no specific facts—only generic references to 'regular basis,' 'senior management team,' and standard security topics (vulnerability assessments, network testing) without naming specific frameworks, dates, roles, or committees.


reasoning: The paragraph discusses cyber insurance and potential financial exposure from cybersecurity incidents, which falls under Strategy Integration. It contains no specific details about coverage amounts, insurers, policy terms, or dates, making it generic boilerplate applicable to any company.


reasoning: The paragraph contains standard materiality disclaimers stating the company is unaware of any material cybersecurity incidents or threats that would affect business strategy or financial condition, which falls under Strategy Integration per the tiebreaker rules. The mention of 'third-party security experts' is generic and unnamed, and the entire text consists of boilerplate language that could apply to any company without modification.


reasoning: The paragraph describes the company's internal risk management process and framework adoption (CIS Controls) to manage cyber risk exposure. It names specific recognized standards (CIS, NIST, ISO 27000) but contains no firm-specific implementation details, dates, headcounts, or quantifiable metrics that would be unique to this particular company.


reasoning: The paragraph describes the company's internal cybersecurity program, framework adoption, and risk management activities (threat monitoring, risk assessments, training), fitting Risk Management Process. It names the NIST Cybersecurity Framework but contains no firm-specific details such as dates, named roles, team compositions, or tools, making it Sector-Adapted.


reasoning: Paragraph primarily presents materiality assessments (no current material effect; 2020 incident resolved without material impact) with the past incident mentioned only briefly as an illustrative example. Per tiebreaker rules, brief incident mention + materiality conclusion as the main point = Strategy Integration. Contains one specific hard fact (year 2020), insufficient for Quantified-Verifiable.


reasoning: The paragraph's central topic is oversight of third-party service providers, including required questionnaires and reviews of independent attestation reports. The disclosure contains no named vendors, specific dates, dollar amounts, tools, or recognized framework standards, consisting entirely of generic vendor risk management practices applicable to any company.


reasoning: Paragraph describes the company's Information Security Program and its activities (monitoring threat landscape, implementing controls), which constitutes internal risk management processes. While it mentions the CISO and oversight committees, the focus is on the program's function rather than the individual's qualifications or board governance details. Contains firm-specific facts: the cybersecurity-specific title 'CISO' and named committees 'TIRC' (Technology and Information Risk Committee) and 'Management Risk Committee'.


reasoning: The paragraph describes generic cyber threats (malicious activity, phishing, malware) faced by financial institutions and potential future impacts without disclosing specific governance structures, management roles, internal processes, or actual incidents. It constitutes forward-looking risk factor language rather than substantive disclosure about the company's cybersecurity program.


reasoning: The paragraph describes the company's internal technical controls and risk management activities (firewalls, patching, backup procedures) rather than governance roles or incidents. It contains firm-specific architectural details—specifically that the company developed its own internal cloud system and uses magnetic tape backups transferred to a fireproof safe—that distinguish it from generic boilerplate.


reasoning: The paragraph provides a detailed narrative of an actual cybersecurity incident, including the specific identification date (October 28, 2023), operational impact (disruption to shipping orders), recovery timeline (mid-December 2023), and quantified financial costs ($1.5 million), satisfying the criteria for Incident Disclosure with multiple independently verifiable facts.


reasoning: This paragraph is a pure cross-reference directing readers to the Risk Factors section (Item 1A) without providing any substantive cybersecurity disclosure regarding governance, processes, incidents, or strategy.


reasoning: Paragraph contains a standalone materiality assessment stating that cybersecurity threats and previous incidents have not materially affected the company, fitting Strategy Integration. It employs standard boilerplate language ('not materially affected', 'no assurance') with no firm-specific details, dates, or quantifiable metrics, making it Generic Boilerplate.


reasoning: Paragraph describes the company's internal cybersecurity processes and cross-functional coordination to identify threats. It specifies the exact departments involved (IT, legal, risk, HR, internal audit), which constitutes a firm-specific organizational detail rather than generic boilerplate.


reasoning: The paragraph describes a generic internal process for keeping management informed about cybersecurity risks, but lacks any specific details about who (no named roles like CISO), how often (no specific cadence), or through what mechanisms this occurs. The reference to 'highest levels of management' and 'Bioxytran' are generic and applicable to any company.


reasoning: This paragraph constitutes a standalone materiality disclaimer regarding the current state of cybersecurity risks, stating no awareness of weaknesses that would materially affect operations. It contains no specific dates, dollar amounts, named systems, or other verifiable facts unique to the company.


reasoning: The paragraph constitutes a materiality disclaimer describing where the company discusses whether cybersecurity risks or previous incidents have materially affected (or are likely to affect) its business strategy, results of operations, or financial condition. Per the guidelines, materiality disclaimers—even boilerplate cross-references appended to materiality assessments—map to Strategy Integration.


reasoning: The paragraph contains a materiality disclaimer stating that cybersecurity risks have not materially affected the company's business strategy, results of operations, or financial condition, which falls under Strategy Integration per the guidelines. It lacks specific details about actual incidents (no dates, scope, or response actions), named frameworks, or cybersecurity-specific roles, consisting only of generic boilerplate language and a cross-reference to Risk Factors.


reasoning: Paragraph identifies management personnel (COO, CFO, General Counsel, and IT management team) as responsible for assessing and managing cybersecurity risks, with board oversight mentioned secondarily. Contains only generic governance references (standard Board committees, generic C-suite titles) and lacks specific cybersecurity roles (CISO/CTO/CIO), dates, frameworks, or verifiable facts that would identify this as unique to Ambarella.


reasoning: The paragraph describes the company's general risk-based approach and mentions implemented cybersecurity policies, which constitutes a description of internal risk management processes. However, it contains no named frameworks, specific dates, dollar amounts, named roles, or unique program identifiers that would distinguish it from any other company's disclosure.


reasoning: The paragraph describes the company's implementation of an Information Security Program with policies for security operations and governance, and discusses general cybersecurity risks facing financial services firms. It contains no specific frameworks, dates, dollar amounts, named tools, or cybersecurity-specific roles that would identify it as unique to this company.


reasoning: The paragraph describes the Board's risk oversight function and delegation of cybersecurity oversight to executive officers (CEO/CFO), making the Board the grammatical subject and focus. However, it contains only generic references to standard C-suite roles and programs without naming specific committees, frameworks, dates, or cyber-specific positions like a CISO.


reasoning: While the paragraph identifies the CISO and CTO and notes the CISO reports to the Risk Committee, the substantive content focuses on the company's internal risk management processes—specifically incident response planning, annual testing protocols, training programs, and security incident logging. Per the Person-vs-Function Test, because the paragraph describes what the roles DO (processes and activities) rather than personal qualifications, credentials, or background, it falls under Risk Management Process. The disclosure includes cybersecurity-specific titles (CISO, CTO) and a named non-generic committee (Risk Committee), making it Firm-Specific rather than Generic Boilerplate, but contains no quantified dates, dollar amounts, headcounts, or named third-party firms/tools to reach Quantified-Verifiable.


reasoning: The paragraph describes immediate response actions taken during an actual cybersecurity incident (assessing nature, scope, and impact), which falls under incident disclosure. However, it contains no specific dates, dollar amounts, named tools, third-party firms, or specific team compositions—only generic references to an 'incident response team' and standard assessment activities that could apply to any company.


reasoning: This paragraph provides a standalone materiality assessment stating that cybersecurity threats have not materially affected the company's business strategy, results of operations, or financial condition. It contains no specific dates (only the generic reference 'as of filing date'), dollar amounts, named roles, or firm-specific details, making it generic boilerplate language that could appear in any SEC filing.


reasoning: The paragraph describes the company's internal cybersecurity processes and safeguards including employee training, incident response capability reviews, cybersecurity insurance, and business continuity mechanisms. It lacks specific dates, named frameworks, named roles (e.g., CISO), named third-party firms, dollar amounts, or other quantified details, making it generic boilerplate that could apply to any company.


reasoning: The paragraph identifies specific cybersecurity management roles (VP, CISO; EVP of Global IT) and their reporting lines (EVP reports to Board via CEO) as grammatical subjects, fitting the Management Role category. It contains firm-specific details including named cybersecurity titles and a 'Risk Subcommittee'.


reasoning: The paragraph describes the company's internal processes for protecting information systems and responding to incidents, including specific risk management strategies (mitigation, transference, acceptance), which falls under Risk Management Process. It identifies the specific role 'Director – Information Systems' as the party responsible for implementing these processes, which is a firm-specific detail that distinguishes this disclosure from generic boilerplate.


reasoning: The paragraph describes the company's internal Enterprise Risk Management Program and documented incident response processes for identifying, assessing, and monitoring cybersecurity risks. While management is the grammatical subject, the focus is on the processes and programs themselves rather than specific management roles, qualifications, or board oversight structures.


reasoning: The paragraph identifies the IT Director as the individual responsible for cyber risk management and details their specific professional qualifications (25 and 15 years of experience), which focuses on the person rather than just the function. It also describes the specific composition of the IT Steering Committee (ITSC), a management-level committee including the Executive Leadership Team.


reasoning: The Audit Committee is the grammatical subject throughout, describing its oversight activities, meeting cadence, and review of cybersecurity risks. While management roles (CISO, CCO/CAO) are mentioned, they are discussed in the context of reporting to and attending meetings with the Board committee.


reasoning: The paragraph describes the company's internal risk management processes, assigning specific oversight responsibilities (program implementation, risk monitoring, incident preparedness) to the Information Security Management Committee, and notes reporting to the specific Board-level Compliance and Information Security Committee.


reasoning: The paragraph describes the audit committee's oversight role and briefing cadence ('at least quarterly') regarding cybersecurity risk management, making Board Governance the appropriate category. The disclosure contains only generic governance terms ('audit committee,' 'management,' 'General Counsel,' 'Information Technology team') and standard program references ('incident response plan') without specific dates, named frameworks, cybersecurity-specific titles (e.g., CISO), named third-party firms, or quantifiable details that would identify this specific company.


reasoning: The paragraph describes a specific cybersecurity incident (MOVEit) that occurred in May 2023 at Umpqua Bank, including detailed response actions (immediate removal/decommissioning of the instance, engagement of an independent forensics firm) and impact scope (no customer data obtained, no business interruption). While it includes a materiality assessment, the primary content is the incident narrative, making this Incident Disclosure. The presence of a specific date (May 2023) and a named product (MOVEit) provides two hard verifiable facts, meeting the Quantified-Verifiable threshold.


reasoning: The paragraph contains generic forward-looking statements about the importance of information systems and the potential for cybersecurity threats to cause material impact, functioning as a risk disclaimer rather than substantive disclosure. It does not describe board oversight, management roles, internal processes, third-party risk, actual incidents, or specific strategic integration elements (budget, insurance, materiality assessments).


reasoning: The paragraph describes the CEO's role in briefing the Audit Committee on cybersecurity risks, with the CEO as the grammatical subject. This fits Management Role (management as subject) rather than Board Governance (which requires the board/committee to be the subject). The disclosure contains only generic references to standard governance roles (CEO, Audit Committee) and a generic annual cadence, with no named frameworks, specific dates, or firm-specific details.


reasoning: The paragraph explicitly references that the company has not yet commenced operations ('once the Company commences operations'), identifying it as a shell company or SPAC. Per the tiebreaker rules, SPACs and shell companies explicitly stating they have no operations or formal processes must be classified as None/Other regardless of incidental mentions of oversight roles or risk acknowledgment.


reasoning: The paragraph describes the company's internal cybersecurity threat operations and incident response capabilities, which falls under Risk Management Process. However, it contains only generic descriptions ('extensive presence', 'continuously and uninterrupted', 'established incident response plans') without naming specific frameworks, roles, dates, headcounts, or tools, making it Generic Boilerplate applicable to any company.


reasoning: The paragraph focuses on the company's commitment to developing and amending processes to address evolving cybersecurity regulations, which aligns with Risk Management Process. While the Board is mentioned, the emphasis is on operational processes rather than governance oversight. The specific reference to the year '2024' in the negative incident statement provides a firm-specific temporal fact, distinguishing it from generic boilerplate.


reasoning: The paragraph describes Board and Audit Committee oversight activities, with the Board and Committee as grammatical subjects performing oversight, receiving reports, and meeting with management. While CISO and CIO are mentioned, they appear in the context of supporting Board oversight functions rather than as the primary focus.


reasoning: The paragraph focuses on the qualifications, tenure, and credentials of the Vice President, IT Security as a person, making it about a management role. It contains multiple hard verifiable facts including a specific duration (26 years) and three named industry certifications (CISSP, CRISC, CISM), exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph provides a standalone materiality assessment regarding cybersecurity risks for the 2024 fiscal year, stating that no material impacts were identified and referencing potential future material effects. This fits Strategy Integration as it focuses on business/financial impact and materiality without describing specific incidents. The specific reference to 'In 2024' constitutes a firm-specific temporal fact.


reasoning: The paragraph describes the company's internal committee structure and processes for managing cybersecurity risks, focusing on what the IT Steering Committee and IT Subcommittee do (review controls, monitor threats, provide guidance) rather than on the personal qualifications of individuals. It identifies specific committees and cybersecurity-specific roles (CISO, CTO, CRO), but does not contain two or more hard verifiable facts like dates, dollar amounts, or named third-party firms.


reasoning: The paragraph describes the company's internal IT strategy (cloud-first, SaaS-based solutions) as part of its risk management approach, mentioning vendors only as a component of that process rather than focusing on vendor oversight or contractual requirements. The naming of SSAE as a specific attestation standard elevates the specificity from generic boilerplate to sector-adapted.


reasoning: The paragraph describes the company's cyber risk management process, investments in protective resources, and detection/response capabilities. While management roles are mentioned (SVP, Operations and VP, Deputy General Counsel), these are not cybersecurity-specific titles (e.g., CISO, CIO) and the focus is on the process and resources rather than the individuals' qualifications or backgrounds. No specific dates, dollar amounts, named standards (NIST, ISO, etc.), third-party firms, products, or cyber-specific titles are present, making this generic boilerplate that could apply to any company.


reasoning: The paragraph describes the ongoing investigation of an actual cybersecurity incident and the current assessment of its scope and potential data compromise, which constitutes Incident Disclosure. However, it contains only generic, non-specific language ('ongoing,' 'not yet completely known,' 'continuing') with no dates, dollar amounts, named entities, or verifiable facts that would identify this specific company's disclosure.


reasoning: The paragraph describes the company's internal processes, mechanisms, and controls for assessing, identifying, and managing cybersecurity risks, including efforts to detect and investigate unauthorized attempts. It also includes a specific dated disclosure confirming no material incident occurred during the fiscal year ended December 31, 2023.


reasoning: The paragraph describes generic internal processes for monitoring IT systems and handling security incidents (detection, evidence collection, severity assessment), but contains no named frameworks, specific dates, organizational titles, or other details unique to SCI Engineered Materials.


reasoning: This paragraph presents a standalone materiality conclusion stating that cybersecurity threats have not materially affected the company, which falls under Strategy Integration per the category definitions. The language is standard boilerplate that could be inserted into any company's filing without modification, containing no specific dates, dollar amounts, named roles, or other verifiable facts unique to the company.


reasoning: The paragraph describes the Company's comprehensive cybersecurity program as part of its ERM approach, covering technical safeguards, incident response planning, third-party risk management, and training processes. It is Firm-Specific because it identifies the 'Vice President of Information Technology' as a specific cybersecurity leadership role and details the specific organizational composition (executive leadership, ERM function, VP of IT) that supports Audit Committee oversight.


reasoning: The paragraph describes standard cybersecurity monitoring, logging, and vulnerability scanning activities performed by an unnamed third-party IT service provider. It contains no named tools, specific dates, frameworks, dollar amounts, or other verifiable facts unique to the company—language that could apply to any organization's basic security operations.


reasoning: The paragraph describes the Audit Committee's oversight activities, including receiving incident reports and quarterly discussions with management about cybersecurity risk, making the Audit Committee the grammatical subject throughout. The mention of the CSO (a cybersecurity-specific executive role) provides a firm-specific detail, though no quantifiable data or named frameworks are present.


reasoning: The paragraph focuses on Board of Directors oversight responsibilities, including review of named internal programs (ICSPP/ICSIRP) and board composition, specifically highlighting Director Sara A. Schmidt's cybersecurity credentials. The Board is the grammatical subject throughout, making Board Governance the appropriate category.


reasoning: The paragraph describes the company's internal protocols for incident reporting and communication to management, stakeholders, and the Board, which falls under incident response planning and risk management processes. It contains no specific details, dates, named committees beyond the standard 'Board,' or unique program identifiers, making it generic boilerplate applicable to any company.


reasoning: The paragraph focuses on the Board of Directors' oversight activities, describing how it receives updates on the cybersecurity program and participates in risk discussions. While employee training is mentioned, it is explicitly framed as 'in addition to Board oversight,' confirming the primary category. The specific title 'Vice President of Information Services' (a cybersecurity-specific functional role) elevates the paragraph from generic boilerplate to Firm-Specific.


reasoning: The paragraph describes the company's internal risk reporting process (quarterly security briefings including alert levels and threat assessments), not the personal qualifications of the CISO or the Risk Committee's governance activities. While the CISO is the grammatical subject, the content focuses on the function and substance of the reporting process, satisfying the Person-vs-Function test for Risk Management Process. Specificity is Firm-Specific due to the cybersecurity-specific title 'CISO' and the named non-generic 'Risk Committee' (distinct from a standard Audit Committee), though no quantifiable data (dates, dollars, headcounts) is present to reach Quantified-Verifiable.


reasoning: The paragraph describes Board and committee oversight of cybersecurity risk, with the Board and its committees (Nominating and Governance, Audit) as grammatical subjects discussing their oversight roles and reporting cadences. The committee names are standard governance bodies and the cadence ('quarterly') is generic, allowing this text to apply to any public company without modification.


reasoning: The paragraph provides a materiality assessment regarding the lack of historical material cybersecurity incidents and identifies general risk categories (operational disruption, data breaches, regulatory exposure) without describing specific internal processes or incidents. This aligns with Strategy Integration, which covers materiality assessments and business impact considerations.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, framework adoption (NIST, ISA/IEC 62443), and ERM integration. While the CISO is the grammatical subject, the content focuses on functional activities (program management, testing, reviews) rather than personal qualifications, satisfying the person-vs-function test for Risk Management Process. It qualifies as Firm-Specific due to the cybersecurity-specific CISO title and the named Enterprise Risk Management Program.


reasoning: The paragraph provides a standalone materiality conclusion regarding cybersecurity risks (stating that prior threats have not materially affected the company but future risks could), which falls under Strategy Integration. It contains no specific dates, dollar amounts, named roles, or frameworks—only generic references to 'enterprise risk management framework' and standard materiality language that could appear in any company's filing.


reasoning: The paragraph describes an actual cybersecurity incident involving stolen Bitcoin (BTC), including the threat actor's method of entry, forensic investigation findings, and remediation actions. It provides a specific date (quarter ended June 30, 2023), a verifiable dollar amount ($560,000), and names a specific third-party entity (Sphere 3D), meeting the threshold for Quantified-Verifiable.


reasoning: Paragraph describes the company's internal cybersecurity processes including threat assessment, penetration testing, system monitoring, protective measures, incident response planning, and employee training. No specific dates, named roles, committees, third-party firms, frameworks, or quantified details are provided; content consists entirely of standard security practices applicable to any company.


reasoning: The paragraph describes the cybersecurity risk management processes, technical controls, and framework alignment implemented by IHM that the company relies upon. While it mentions third-party providers for tools, the central focus is on the risk management functions (detection, monitoring, response) rather than vendor oversight. Specificity is Firm-Specific due to identification of IHM as the specific property manager, the detail about shared corporate office space, and reference to the NIST Cybersecurity Framework.


reasoning: The paragraph discusses the company's maintenance of cybersecurity insurance and the scope of coverage, which falls under the Strategy Integration category (cyber insurance). It contains no specific details such as coverage limits, named insurers, policy terms, or specific dates, making it generic boilerplate applicable to any company.


reasoning: The paragraph describes the company's internal governance structure for overseeing cybersecurity risk through specific management committees (OROC and IT Steering Committee), their meeting cadence, and cross-functional composition, which constitutes a risk management process. It is firm-specific because it names distinct internal committees and details the specific departmental makeup (IT/Security, Legal, Accounting, Operational Risk Management) rather than using generic descriptions.


reasoning: The paragraph describes the company's internal processes for monitoring risks and identifying vulnerabilities using a specific tool, which falls under Risk Management Process. The disclosure identifies 'Coalition Control' as a specific named tool/product used by the company, which is a firm-specific fact, but does not contain a second hard verifiable fact (such as dates, dollar amounts, or headcounts) needed for Quantified-Verifiable.


reasoning: The paragraph centrally addresses third-party vendor oversight, describing onboarding and monitoring processes for service providers and acknowledging limitations in controlling or monitoring their cybersecurity practices. It lacks specific dates, named vendors, dollar amounts, headcounts, or other verifiable facts, consisting instead of generic risk disclosure language that could apply to any company.


reasoning: The paragraph describes the company's internal risk management processes, including detection capabilities and incident notification procedures, rather than focusing on an individual's qualifications or an actual incident. While it mentions the 'Head of Information Security,' the focus is on the collaborative function (evaluating and addressing risks) rather than the person, satisfying the person-vs-function test for Risk Management Process. The cybersecurity-specific title provides one firm-specific detail, but there are no additional hard verifiable facts (dates, dollar amounts, named vendors) to reach Quantified-Verifiable.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes, including implementation of security technologies, internal controls, network resiliency, redundancy, disaster recovery, and backup systems. However, it contains no specific facts such as named frameworks, cybersecurity roles, dates, dollar amounts, third-party firms, or tools, making it generic boilerplate that could apply to any company.


reasoning: Paragraph enumerates the company's internal cybersecurity processes (risk assessments, security controls, incident response planning, and third-party risk management). While it mentions external service providers and third-party risk management, these are components of the overall internal program rather than the central topic. The language is entirely generic—no named frameworks, specific dates, quantified metrics, cybersecurity-specific titles (e.g., CISO), or named vendors are provided, allowing this text to apply to virtually any company.


reasoning: The paragraph describes internal risk management processes (reporting cadence, controls assessment, third-party oversight) rather than the personal qualifications of the Director of Compliance, satisfying the Person-vs-Function test for Risk Management Process. It contains no specific dates, quantified metrics, named frameworks, or cybersecurity-specific role titles (e.g., CISO) from the IS list, and 'regular reports' is a vague cadence, making it Generic Boilerplate.


reasoning: The paragraph contains a standalone materiality disclaimer stating that cybersecurity incidents have not materially affected the company's financial condition or operations, which falls under Strategy Integration per the tiebreaker rules. It references generic 'processes' and an unnamed 'IT consultant' without naming specific frameworks, tools, dates, or individuals, rendering it generic boilerplate.


reasoning: The paragraph describes board-approved committees (ITAC and ERM) chaired by board members that provide oversight of cybersecurity risk, along with an internal management committee (ITSC) and specific cybersecurity leadership roles participating in governance, making the board and its committees the primary grammatical subjects.


reasoning: This paragraph is a pure cross-reference to Part I, Item 1A Risk Factors and contains no substantive cybersecurity disclosure. It merely directs readers to another section for information on operational and security risks, functioning as a navigational pointer rather than describing governance, management, processes, or incidents.


reasoning: The paragraph describes an actual cybersecurity incident involving confirmed data exfiltration and ongoing investigation of compromised IT systems, which fits the Incident Disclosure category. However, it contains only generic language ('certain information,' 'accessed IT systems') without specific dates, named systems, scope quantification, or other identifying details that would distinguish this incident disclosure from any other company's filing.


reasoning: The paragraph identifies specific cybersecurity leadership roles (CISO and CIO), their reporting lines, and the CISO's specific qualifications (40 years experience, 20+ in security). This centers on management personnel rather than processes. While it contains specific numerical details about experience, it lacks the hard verifiable facts (dates, dollar amounts, headcounts, named vendors/tools) required for Quantified-Verifiable, placing it at Firm-Specific.


reasoning: The paragraph describes the company's internal cybersecurity program, controls, and incident procedures, which falls under risk management processes. While it names the NIST Cybersecurity Framework as its basis, it contains no firm-specific details such as named roles, dates, headcounts, or unique internal program identifiers.


reasoning: The paragraph describes the company's internal cybersecurity processes (monitoring systems, incident response practices, and employee training) but uses entirely generic language ('standard incident response practices', 'periodic trainings') without naming specific tools, frameworks, dates, numbers, or roles that would identify these as unique to Select Water Solutions.