fact: Board's Cybersecurity Special Committee

fact: incident response and breach management processes

fact: containing, eliminating and recovering

reasoning: The paragraph primarily outlines the company's four-step incident response and breach management methodology, categorizing it as Risk Management Process. It reaches Firm-Specific specificity by naming a unique board-level committee (Cybersecurity Special Committee).


content_category: Strategy Integration

fact: malware

fact: computer virus attacks

category_confidence: high

specificity_confidence: high

reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, placing it in Strategy Integration. Specificity is Domain-Adapted due to the mention of specific threat types like malware and computer viruses.

provider: google

stage: benchmark


content_category: Third-Party Risk

fact: Service Organization Controls (SOC) reports

type: framework

fact: Vendor Management team

fact: vendor management office

reasoning: The paragraph focuses entirely on the oversight of third-party service providers, including due diligence, contractual requirements, and ongoing monitoring. Specificity is Firm-Specific due to the mention of the internal Vendor Management team/office, alongside domain terms like SOC reports.


content_category: Risk Management Process

fact: Enterprise Risk Management Committee

fact: Chief Information Officer

fact: Chief Risk Officer

fact: Information Security Policy and Program

fact: internal and external penetration test

reasoning: The paragraph describes the activities of the cybersecurity program, including information systems audits, penetration testing, and risk assessments, making it Risk Management Process despite the initial mention of management committee composition. The specificity is Firm-Specific due to the naming of specific management roles (Chief Information Officer, Chief Risk Officer) and internal committees/programs.


fact: National Institute of Standards and Technology

fact: International Organization for Standardization

fact: confidentiality, security and availability

reasoning: The paragraph primarily describes the integration of cybersecurity into the broader enterprise risk management program and the frameworks used, fitting Risk Management Process. Specificity is Domain-Adapted due to the mention of NIST, ISO, and the confidentiality/availability triad.


reasoning: The paragraph explicitly states conclusions about whether cybersecurity risks or prior incidents have materially affected the company's operations, business strategy, results of operations, or financial condition, which aligns with the Strategy Integration category. The language is entirely generic and lacks any domain-specific terms, firm-specific details, or verifiable facts, resulting in a Generic Boilerplate specificity level.


reasoning: The paragraph provides a high-level, generic statement about adapting internal controls and processes to protect systems, which falls under risk management processes, along with a cross-reference to Item 1A.


content_category: None/Other

reasoning: The paragraph is a pure cross-reference to the Risk Factors section in Item 1A, containing no substantive cybersecurity disclosure.


reasoning: The paragraph provides introductory context about the company's reliance on technology and general security risks, without detailing any specific cybersecurity measures, governance, or impacts.


fact: early 2024

fact: SomaLogic Operating Co, Inc.

fact: ongoing ISO 27001 compliance certification

reasoning: The paragraph describes the integration and review of cybersecurity policies, procedures, and tools following a merger, which falls under Risk Management Process. The specificity is Quantified-Verifiable because it names a specific acquired company (SomaLogic Operating Co, Inc.) and cites an externally verifiable certification (ISO 27001).


content_category: Board Governance

fact: Vice President, Information Security and Privacy

fact: Senior Vice President, Chief Strategy and Digital Officer

reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity risk and the reporting structure from management to the committee, making it Board Governance. The specificity is Firm-Specific due to the inclusion of specific VP-level and SVP-level titles with security/digital qualifiers.


reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity, including ad hoc conversations and annual updates, placing it in Board Governance. It contains only generic governance language and cadences, lacking any domain-specific terminology or firm-specific details.


reasoning: The paragraph describes the reporting structure from management to the Board and Audit Committee regarding cybersecurity risks and incidents, which falls under Board Governance. The language is entirely generic with no domain-specific terminology, firm-specific roles, or verifiable metrics.


content_category: Incident Disclosure

fact: early 2019

fact: ransomware

fact: persistence mechanisms

fact: exchange on-premises accounts

reasoning: The paragraph primarily describes a specific historical cybersecurity incident (a 2019 ransomware attack), detailing the investigation, recovery, and forensic findings, which clearly falls under Incident Disclosure. The specificity is Quantified-Verifiable because it provides a specific timeframe ('early 2019') for a real, historical event.


content_category: Management Role

reasoning: The paragraph describes management's responsibility for developing cybersecurity programs, their expertise (education and prior work experience), and how they are informed by their teams. This aligns with Management Role. The language is entirely generic with no domain terms, firm-specific roles, or verifiable facts.


fact: HITRUST

fact: penetration testing

fact: threat modeling

fact: network firewalls

fact: access controls

fact: vulnerability scanners

fact: intrusion prevention and detection systems

fact: identity and access management systems

fact: NIST

fact: Incident Response Plan

reasoning: The paragraph provides a comprehensive overview of the company's cybersecurity risk management processes, including framework alignment, technical tools, training, and incident response planning. The specificity is Firm-Specific due to the detailed list of internal security measures and the specific named frameworks (HITRUST, SOC2, NIST) and tools used.


reasoning: The paragraph is a standard cross-reference to the Risk Factors section (Item 1A) and contains no substantive cybersecurity program disclosures.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, aligning with Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section (Item 1A) and quotes hypothetical risk language, containing no substantive description of the company's cybersecurity program or governance.


reasoning: The paragraph explicitly describes the Board's delegation of cybersecurity risk oversight to the Audit Committee, which falls squarely under Board Governance. The language is entirely generic, lacking any domain-specific terminology or firm-unique details.


fact: Onex Corp.

reasoning: The paragraph is a pure cross-reference directing the reader to the Risk Factors section, making it None/Other. It contains the specific name of the company's affiliate (Onex Corp.), elevating the specificity to Firm-Specific.


fact: cyberthreat landscape

fact: breach notification and response processes

reasoning: The paragraph describes the use of third-party service providers to assess and support the company's internal cybersecurity program, which falls under Risk Management Process rather than Third-Party Risk (which is for vendor oversight). The specificity is Domain-Adapted due to the use of cybersecurity-specific terms like cyberthreat landscape and breach notification.


fact: Global Security Organization

fact: ERM Steering Committee

fact: CSO

reasoning: The paragraph describes the governance chain and reporting structure for cyber risk, detailing how management teams like the Global Security Organization report up to the Risk Committee of the Board. Specificity is Firm-Specific due to the naming of specific internal management roles and committees like the CSO and ERM Steering Committee.


fact: ransomware attacks

fact: phishing attacks

fact: insider threats

fact: computer viruses

reasoning: The paragraph explicitly states a backward-looking materiality assessment regarding past cyber incidents ('none of which... have had a material impact'), placing it in Strategy Integration. Specificity is Domain-Adapted due to the use of specific threat terminology like ransomware, phishing, and insider threats.


fact: vulnerability scans

fact: security questionnaires

reasoning: The paragraph focuses entirely on managing cybersecurity risks associated with third-party service providers, including contractual obligations and assessments. It reaches Domain-Adapted specificity by mentioning specific cybersecurity practices like vulnerability scans and security questionnaires.


reasoning: The paragraph explicitly states a conclusion about whether cybersecurity incidents have materially affected or are reasonably likely to materially affect the Company's business strategy, results of operations, or financial condition, which aligns with the Strategy Integration category. It contains no domain terms, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph primarily describes the Board and Audit Committee's oversight of cybersecurity risks and its integration into the ERM process. It contains no domain-specific cybersecurity terminology, firm-specific roles, or verifiable metrics, making it generic boilerplate.


fact: Paresh Patel

reasoning: The paragraph explicitly discusses the Board's receipt of cybersecurity reports and highlights the IT expertise of a specific board member, placing it squarely in Board Governance. The inclusion of the named board member (Paresh Patel) elevates the specificity to Firm-Specific.


fact: Security Governance Council (the "SGC")

fact: CISO

fact: Operations, Information Technology, Finance, Internal Audit, Legal, Human Resources and Organizational Development, and Risk Management

reasoning: The paragraph primarily describes the management-level organizational structure for cybersecurity, detailing the Security Governance Council (SGC), its chair (CISO), and its cross-functional departmental membership, which falls under Management Role. The specificity is Firm-Specific due to the named internal committee (SGC), the specific CISO role, and the detailed list of participating departments.


reasoning: The paragraph focuses exclusively on the company's procedures for managing cybersecurity risks associated with third-party vendors and service providers. The language used is generic and lacks specific domain terminology or firm-specific details.


fact: Chief Technology Officer

reasoning: The paragraph describes the responsibilities and expertise of management roles (CTO and IT Director) in handling cybersecurity, fitting the Management Role category. Specificity is Firm-Specific due to the mention of the Chief Technology Officer.


reasoning: The paragraph explicitly states a conclusion about whether cybersecurity threats are reasonably anticipated to have a material effect on the business strategy, results of operations, or financial condition, which aligns with the Strategy Integration category. The language is generic and lacks any domain-specific terms, firm-specific details, or verifiable facts, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph focuses exclusively on the oversight and requirements imposed on third-party service providers regarding their security measures and breach reporting, fitting the Third-Party Risk category. The language is entirely generic with no specific domain terms, firm-specific details, or verifiable metrics.


fact: Fidelity

reasoning: The paragraph focuses entirely on the oversight of third-party service providers and vendor cybersecurity controls, making it Third-Party Risk. It is Firm-Specific because it explicitly names Fidelity as the entity executing the vendor management program on behalf of the Trust.


fact: Breach Response Team

fact: detection, mitigation and remediation strategies

reasoning: The paragraph describes the incident response preparation activities of the company's cybersecurity program, specifically tabletop exercises. It is classified as Firm-Specific due to the mention of the specifically named 'Breach Response Team'.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section (Item 1A), which falls under None/Other and therefore automatically receives Generic Boilerplate specificity.


reasoning: The paragraph describes the reporting chain from the Global Director of IT to the CEO/CFO and up to the audit committee and board, making it a Board Governance disclosure. It lacks domain-specific terminology, firm-specific named security roles (Director of IT lacks a security qualifier), or verifiable metrics, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph primarily discusses the integration of cybersecurity into the company's Enterprise Risk Management (ERM) program and outlines its general approach to managing cyber risks, fitting the Risk Management Process category. The language is highly generalized and lacks specific domain terminology, firm-specific details, or verifiable metrics, resulting in a Generic Boilerplate specificity level.


fact: Our Town (hotel manager)

reasoning: The paragraph focuses on the cybersecurity risks associated with third parties, specifically the company's reliance on its hotel manager and franchisors. It is Firm-Specific because it explicitly names the hotel manager, 'Our Town'.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, and mentions cyber insurance, placing it in Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the board's delegation of cybersecurity oversight to the Audit Committee and the General Counsel's role, making it a standard governance-chain description. It contains only generic roles and committees, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks and incidents on the company's business strategy and financial condition, aligning with Strategy Integration. It contains only boilerplate SEC language and a generic cross-reference, lacking any specific cybersecurity facts.


reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risks, including reporting from the Chief Financial Officer, making it Board Governance. It contains no domain-specific cybersecurity terms, firm-specific roles (CFO and Audit Committee are generic), or verifiable facts, resulting in Generic Boilerplate specificity.


fact: penetration testing

fact: CIS Critical Security Controls

reasoning: The paragraph contains a clear materiality assessment regarding the impact of cybersecurity risks on the company's business strategy and financial condition, making it Strategy Integration. The specificity is Domain-Adapted due to the mention of penetration testing and the CIS Critical Security Controls framework.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity incidents on the company, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes how the Audit Committee and full Board receive briefings and presentations on cybersecurity from management, making it a Board Governance paragraph. The mention of the 'Chief Technology Officer' elevates the specificity to Firm-Specific.


reasoning: The paragraph describes the Audit Committee's oversight responsibilities and management's reporting structure to the Board, placing it in Board Governance. It contains only generic governance language without any domain-specific terminology, firm-specific details, or verifiable metrics.


fact: Vice President and Chief Information Officer

fact: Director of Information Security

fact: 27 years of technology leadership experience

type: quantified

fact: Doctor of Business Administration

fact: 27 years of experience in infrastructure and security operations

fact: degree in Information Technology Management

fact: Information Security Committee

fact: Executive Information Security Oversight Committee

reasoning: The paragraph primarily describes the management structure, roles, reporting lines, and qualifications of the cybersecurity leadership team, making it Management Role. The specificity is Quantified-Verifiable due to the specific years of experience (27 years) and specific degrees mentioned for the leadership roles.


fact: Director of Global Information Systems

reasoning: The paragraph primarily describes the Board of Directors' and Audit Committee's oversight of cybersecurity risks, including reporting structures and cadences. Specificity is Firm-Specific due to the mention of the specific management title (Director of Global Information Systems) responsible for reporting to the committee.


fact: over thirty years of experience

fact: threat intelligence

reasoning: The paragraph describes the responsibilities and experience of the Head of IT, placing it in Management Role. It reaches Quantified-Verifiable specificity by stating the Head of IT has over thirty years of experience, which is an externally verifiable claim.


fact: CISO

fact: certificate in Cybersecurity Oversight from the Carnegie Mellon University Software Engineering Institute

reasoning: The paragraph primarily describes the leadership role, responsibilities, and qualifications of the CISO and the corporate information security organization, fitting Management Role. The specificity is Quantified-Verifiable due to the verifiable claim that the CISO holds a specific certificate from Carnegie Mellon University.


fact: National Institute of Standards and Technology

fact: International Organization for Standardization

reasoning: The paragraph primarily discusses the Board's active involvement in overseeing the risk management program, including cybersecurity, making it Board Governance. The specificity is Domain-Adapted due to the mention of NIST and ISO frameworks.


reasoning: The paragraph is solely a cross-reference to the Risk Factors section (Item 1A) and contains no substantive cybersecurity disclosure.


fact: Onex Corp.

reasoning: The paragraph focuses entirely on the processes used to assess and manage cybersecurity risks associated with third-party vendors, including onboarding assessments and contractual protections. It reaches Firm-Specific specificity by naming the specific external manager (Onex Corp.) responsible for executing these processes.


reasoning: The paragraph explicitly states a conclusion regarding the material effect of cybersecurity risks and incidents on the company's results of operations and financial condition, which falls under Strategy Integration. The specificity is Generic Boilerplate because it contains only negative assertions and reporting period context, lacking any domain terminology, firm-specific details, or externally verifiable cybersecurity facts.


reasoning: The paragraph explicitly describes the oversight responsibilities of the Board of Directors and the Audit Committee regarding cybersecurity. It contains only generic governance language and lacks specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph primarily describes the governance reporting chain, detailing how the CFO manages risk and reports to the Audit Committee, which in turn oversees the risk and reports to the full Board. The specificity is Generic Boilerplate because it relies entirely on generic corporate roles (CFO, Audit Committee, Chairman) and standard enterprise risk management terminology without any cybersecurity-specific domain terms or firm-unique details.


fact: Ontrack software solution

reasoning: The paragraph describes the company's risk monitoring activities and tools, placing it in Risk Management Process. It achieves Quantified-Verifiable specificity by naming the specific software solution ('Ontrack') used for tracking risk assessments and incidents.


fact: Chief Information Consultant

reasoning: The paragraph primarily describes the responsibilities of the Chief Information Consultant and CFO in evaluating and reporting cybersecurity risks, fitting the Management Role category. The specificity is Firm-Specific due to the explicit mention of the Chief Information Consultant role.


reasoning: The paragraph provides a high-level introduction to the company's cybersecurity program and its goals of safeguarding information, making it primarily about the risk management process. It relies entirely on generic boilerplate language and standard governance terms (Audit Committee) without any specific domain terminology or firm-unique details.


reasoning: The paragraph is a pure cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosure.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, which aligns with the Strategy Integration category. The text consists entirely of standard materiality boilerplate and a cross-reference, containing no specific facts, resulting in a Generic Boilerplate specificity level.


fact: Senior Vice President and Chief Information Officer ("CIO")

fact: over 25 years of IT Risk Management experience

fact: more than 30 years of collective information and product security experience

reasoning: The paragraph primarily describes management's organizational structure and responsibilities, focusing on the CIO and the cybersecurity team. It reaches Quantified-Verifiable specificity by including specific, verifiable lower bounds for the years of experience held by the CIO and the team.


fact: SVP of IT Security

reasoning: The paragraph primarily describes the board's oversight structure, specifically detailing how and when the Audit Committee is briefed on cybersecurity risks by management. The specificity is Firm-Specific due to the mention of the 'SVP of IT Security' role.


fact: Chief Information Officer ("CIO")

fact: Chief Information Technology Architect & Chief Information Security Officer ("CISO")

reasoning: The paragraph describes the reporting structure and frequency of cybersecurity updates to the Committee and the full Board, placing it in Board Governance. It reaches Firm-Specific specificity by naming specific executive roles (CIO, Chief Information Technology Architect & CISO) responsible for these presentations.


fact: Chief Information Security Officer ("CISO")

fact: information technology ("IT") security teams

reasoning: The paragraph primarily describes the company's cybersecurity risk management processes, their integration into ERM, and business continuity goals. The specificity is Firm-Specific due to the explicit mention of the CISO role and IT security teams.


fact: penetration testing

reasoning: The paragraph primarily describes the company's cybersecurity risk management activities, including the use of consultants, frameworks, and third-party evaluations. Specificity is Domain-Adapted due to the inclusion of cybersecurity-specific terminology like penetration testing.


fact: Vice President of Information Systems and Architecture (VP of IT)

reasoning: The paragraph primarily describes the leadership role, responsibilities, and reporting structure of the VP of Information Systems and Architecture, placing it in Management Role. The specificity is Firm-Specific due to the explicitly named VP-level IT role.


reasoning: The paragraph merely provides a definitional cross-reference to SEC Regulation S-K Item 106, containing no substantive cybersecurity disclosure.


fact: December 2021

fact: March 2024

fact: approximately two weeks

fact: within one week

fact: end point protection software

reasoning: The paragraph details two specific past cybersecurity incidents, including their timing, operational impact, and remediation efforts, making it an Incident Disclosure. It includes verifiable dates (December 2021, March 2024) and durations (two weeks, one week), elevating the specificity to Quantified-Verifiable.


fact: penetration tests

category_confidence: medium

reasoning: The paragraph primarily describes management's responsibilities and involvement in cybersecurity, including their oversight duties and membership on the incident response team. The specificity is Domain-Adapted due to the inclusion of the cybersecurity-specific term 'penetration tests'.


reasoning: The paragraph primarily describes the Board of Directors' oversight of cybersecurity, including reporting cadences, presentations from management, and escalation processes. It lacks domain-specific terminology, firm-specific named roles (as 'Director of IT' lacks a security qualifier per the rules), or verifiable metrics, resulting in a generic boilerplate classification.


reasoning: The paragraph describes the Audit Committee's oversight of cybersecurity risks and the reporting cadence from management, placing it in Board Governance. It contains only generic governance and ERM terminology with no domain-specific, firm-specific, or verifiable facts.


reasoning: The paragraph explicitly states management's conclusions regarding the material impact of past cybersecurity incidents and the likelihood of future material impacts on the business strategy and financial condition, aligning with Strategy Integration. It contains only generic boilerplate language without any domain-specific terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph explicitly states a conclusion about the material impact of cybersecurity threats on the company's financial position and operations, fitting the Strategy Integration category. It contains only generic boilerplate language and negative assertions without any specific domain terms, firm-specific details, or verifiable facts.


fact: Topper Group employees

reasoning: The paragraph explicitly states a conclusion regarding the material impact of past cybersecurity incidents on the business, aligning with Strategy Integration. It includes the firm-specific mention of 'Topper Group employees', elevating the specificity to Firm-Specific.


reasoning: The paragraph is a cross-reference to the Risk Factors section detailing hypothetical risks and potential consequences, containing no substantive description of the company's cybersecurity program or actual incidents.


fact: CTO, Vaidyanathan Raghavan

fact: General Manager of Technology at Wayfair

fact: Master of Science in Electrical Engineering degree from the University of Minnesota

fact: Vice President of Information Technology and Security, Mr. Brendan Hamilton

fact: Certified Information Systems Security Professional

reasoning: The paragraph focuses entirely on the specific management personnel responsible for cybersecurity, detailing their titles, names, and backgrounds, which classifies it as Management Role. The inclusion of verifiable facts such as specific degrees from named universities, past employment at named companies, and specific certifications (CISSP) elevates the specificity to Quantified-Verifiable.


reasoning: The paragraph focuses on the responsibilities, qualifications, and training of the management team and information systems organization, fitting the Management Role category. It lacks specific domain terminology, named roles, or verifiable facts, making it generic boilerplate.


fact: phishing attacks

fact: malware infections

reasoning: The paragraph provides a materiality assessment regarding past cyber attempts, concluding they would not have had a material adverse effect, which aligns with Strategy Integration. Specificity is Domain-Adapted due to the mention of specific threat types like phishing and malware.


reasoning: The paragraph details the responsibilities of management roles (Senior Director of IT and General Counsel) in overseeing cybersecurity, placing it in Management Role. It lacks domain-specific terminology, firm-specific security titles (Senior Director of IT lacks a security qualifier), or verifiable metrics, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses exclusively on the processes for assessing and conducting due diligence on information technology suppliers, fitting the Third-Party Risk category. The language is entirely generic, lacking specific domain terminology, firm-specific details, or verifiable metrics.


fact: second ISO 27001 certification

reasoning: The paragraph describes the company's risk management activities, including controls testing, employee training, and third-party assessments. It reaches Quantified-Verifiable specificity by stating the verifiable fact that the company obtained its second ISO 27001 certification.


reasoning: The paragraph focuses entirely on the Board of Directors' oversight responsibilities, expertise, and resource allocation for the cybersecurity program. It contains only generic governance language without any domain-specific terminology or firm-specific details.


fact: security questionnaires

reasoning: The paragraph focuses entirely on the vendor management process and how the company assesses and mitigates cybersecurity risks associated with third-party service providers. Specificity is Domain-Adapted due to the mention of specific assessment methods like security questionnaires.


fact: IT Security Steering Committee

fact: VP of Software Engineering

fact: Director of Information Systems and Security

fact: IT Security Team

fact: over 40 years of experience

reasoning: The paragraph primarily describes the management-level organizational structure for cybersecurity, detailing the IT Security Steering Committee, its leadership, and the IT Security Team's composition and responsibilities. The specificity is Quantified-Verifiable due to the verifiable claim of 'over 40 years of experience' for the named roles.


reasoning: The paragraph consists entirely of hypothetical risk statements ('could materially harm') and a cross-reference to the Risk Factors section, lacking any substantive description of the company's actual cybersecurity program or strategy.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section (Item 1A) and contains no substantive cybersecurity disclosures.


fact: CTO

reasoning: The paragraph focuses on management's responsibilities and oversight of the cybersecurity program, specifically naming the CTO. It is classified as Management Role and Firm-Specific due to the inclusion of the CTO title.


fact: Senior Director, Information Technology

fact: Incident Response Team

fact: over twenty years of experience

reasoning: The paragraph primarily describes the management structure and personnel responsible for cybersecurity, including specific roles and the Senior Director's verifiable years of experience.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the Board's oversight of cybersecurity risks and the reporting cadence from management, fitting Board Governance. It contains only generic language with no domain-specific terminology, firm-specific details, or verifiable metrics.


fact: GDPR

reasoning: The paragraph primarily describes the company's cybersecurity risk management program, including its framework alignment and processes for identifying and addressing threats. The specificity is Domain-Adapted due to the mention of specific frameworks (ISO 27001, NIST 800-53, GDPR), but lacks firm-specific or verifiable facts.


reasoning: The paragraph explicitly states conclusions about the material impact of cybersecurity threats and incidents on the company's business strategy, results of operations, and financial condition, which aligns with the Strategy Integration category. It contains no domain terms, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


fact: information security risk committee

fact: Chief Information Security Officer ("CISO")

reasoning: The paragraph primarily describes the management-level organizational structure, specifically the information security risk committee and the CISO's leadership role. Specificity is Firm-Specific due to the named management committee and CISO role.


fact: February 2024

reasoning: The paragraph details the Board and Audit Committee's oversight responsibilities and reporting structure for cybersecurity risks, which falls under Board Governance. The inclusion of a specific date (February 2024) for the Board's delegation action elevates the specificity to Quantified-Verifiable.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity incidents on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only generic boilerplate language and negative assertions without any specific domain terms or verifiable facts.


reasoning: The paragraph is a generic concluding statement about the goals of the company's risk management strategies without describing any substantive cybersecurity measures, processes, or impacts, making it None/Other. It contains no domain-specific terminology, firm-specific details, or verifiable facts, resulting in a Generic Boilerplate specificity.


fact: National Institute of Standards and Technology Cybersecurity Framework's (NIST CSF)

fact: Identify, Protect, Detect, Respond, and Recover

reasoning: The paragraph describes the company's cybersecurity risk management program and its alignment with a specific framework, placing it in Risk Management Process. Specificity is Domain-Adapted due to the explicit reference to the NIST CSF and its core functions.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity incidents on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains no domain-specific terminology, firm-specific cybersecurity facts, or externally verifiable claims, resulting in a Generic Boilerplate specificity.


fact: ransomware

fact: denial-of-service

fact: advanced, persistent, or organized actors

reasoning: The paragraph describes the cybersecurity threat landscape the company's program is designed to guard against, fitting into the broader risk management context. The specificity is Domain-Adapted due to the inclusion of specific cybersecurity threat terminology like ransomware and denial-of-service.


reasoning: The paragraph describes the board's oversight of cybersecurity risk and delegation to the audit committee, placing it in Board Governance. It contains only generic governance language with no domain-specific terminology or firm-specific details.


fact: Chief Information Officer ("CIO")

reasoning: The paragraph primarily describes the Board's oversight of cybersecurity risks, including regular reviews and updates from management, making it Board Governance. The mention of the specific role 'Chief Information Officer' elevates the specificity to Firm-Specific.


fact: vulnerability management

reasoning: The paragraph primarily describes the responsibilities and reporting lines of management, specifically the Principal Accounting Officer, in handling and escalating cybersecurity incidents. The specificity is Domain-Adapted due to the use of the cybersecurity-specific term 'vulnerability management', while the roles mentioned (Principal Accounting Officer) are standard corporate governance positions.


reasoning: The paragraph explicitly describes the board of directors' oversight of cybersecurity risk and its delegation to the Audit Committee, placing it squarely in Board Governance. The language relies entirely on generic corporate governance terms without any domain-specific cybersecurity terminology or firm-specific details.


fact: CCO

fact: Adviser

reasoning: The paragraph explicitly describes management's responsibilities, expertise, and monitoring processes regarding cybersecurity, making it a clear fit for Management Role. The specificity is Firm-Specific because it identifies the CCO as a key figure in this process and references reliance on the Adviser's personnel.


reasoning: The paragraph describes the reporting chain from the executive team to the Board's audit committee regarding cybersecurity risks, which falls under Board Governance. It contains only generic language and standard corporate structures (audit committee), resulting in a Generic Boilerplate specificity.


fact: cybersecurity incident response team

reasoning: The paragraph primarily describes the organizational structure and roles for handling incidents, specifically detailing the cybersecurity incident response team and its escalation paths to management and the audit committee. The specificity is Firm-Specific due to the identification of a named internal team.


reasoning: The paragraph focuses exclusively on the oversight, selection, and due diligence of third-party service providers regarding cybersecurity risks. The language is entirely generic, lacking any specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph describes the Board and Audit Committee's oversight responsibilities for cybersecurity risk management, placing it squarely in Board Governance. It contains only generic governance and risk management terminology, resulting in a Generic Boilerplate specificity level.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section (Item 1A) and contains no substantive cybersecurity program details.


reasoning: The paragraph focuses entirely on the oversight of third-party vendors, including due diligence and contractual security requirements. The language used is generic and lacks specific domain terminology, firm-specific details, or verifiable metrics.


fact: confidentiality, integrity, and availability

fact: National Institute of Standards and Technology Cybersecurity Framework (NIST CSF)

fact: HIPAA

fact: Service Organization Control Type 2 (SOC 2 Type II)

fact: Sarbanes-Oxley IT General Controls (SOX ITGC)

reasoning: The paragraph describes the company's cybersecurity risk management program and its adoption of specific industry frameworks, which falls under Risk Management Process. The specificity is Domain-Adapted because it lists several specific cybersecurity and IT control frameworks (NIST CSF, SOC 2 Type II, SOX ITGC) but explicitly disclaims holding verifiable certifications for them.


reasoning: The paragraph is entirely a cross-reference to the Risk Factors section (Item 1A) and contains no substantive cybersecurity disclosure.


reasoning: The paragraph is a purely introductory, boilerplate statement about the general importance of cybersecurity, containing no substantive disclosure about processes, governance, or strategy.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


fact: third quarter of fiscal year 2023

fact: zero-day vulnerability

reasoning: The paragraph primarily describes a specific material cybersecurity incident that occurred in the third quarter of fiscal year 2023, including its nature (zero-day vulnerability in a third-party vendor's file transfer application) and the resulting expenses. The inclusion of a specific timeframe ('third quarter of fiscal year 2023') makes it Quantified-Verifiable.


reasoning: The paragraph is a generic introductory statement about the company's commitment to cybersecurity, containing no substantive disclosure about processes, governance, or strategy.


fact: Mr. Lee

reasoning: The paragraph describes the reporting of cybersecurity incidents to the Board and Audit Committee, falling under Board Governance. It includes a named individual (Mr. Lee) responsible for this reporting, making it Firm-Specific.


fact: Senior Vice President – Technology Solutions

fact: reports directly to our President

fact: served in this role for over four years

fact: more than 25 years of experience in the aggregate

fact: more than ten years with the Company

reasoning: The paragraph describes the governance chain, starting and ending with the audit committee's oversight responsibilities and reporting cadence, making it primarily Board Governance. The specificity is Quantified-Verifiable because it provides specific, verifiable lower bounds for the Senior Vice President's years of experience.


fact: ISO

fact: CISO

reasoning: The paragraph primarily describes the board's oversight structure, specifically the audit committee's role and the reporting chain for security incidents, making it Board Governance. The specificity is Firm-Specific due to the mention of specific cybersecurity leadership roles (ISO, CISO).


reasoning: The paragraph outlines the high-level objectives of the company's cybersecurity measures, categorizing it as Risk Management Process. It includes the domain-specific concept of the CIA triad (integrity, confidentiality, and availability), making it Domain-Adapted.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, aligning with Strategy Integration. It contains no domain-specific terminology, firm-specific cybersecurity details, or externally verifiable facts, making it generic boilerplate.


reasoning: The paragraph explicitly assesses the material impact of cybersecurity threats on the company's business strategy and financial condition, and discusses cybersecurity insurance, placing it squarely in Strategy Integration. The language is entirely generic with no domain-specific terminology, firm-specific details, or verifiable metrics.


fact: Mr. Tao

fact: more than 20 years of professional experience

reasoning: The paragraph details the professional background and qualifications of a specific management individual, placing it in Management Role. It includes a verifiable lower bound of experience ('more than 20 years'), making it Quantified-Verifiable.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains only generic boilerplate language with no domain-specific terminology, firm-specific details, or verifiable facts.


reasoning: The paragraph describes the Board and Audit Committee's oversight of cybersecurity risks, placing it in Board Governance. It contains only generic boilerplate language with no domain-specific terminology, firm-specific details, or verifiable metrics.


fact: NIST Framework

fact: monitoring and detection tools

fact: vulnerabilities

reasoning: The paragraph describes the company's cybersecurity program activities, including its adoption of the NIST Framework and use of monitoring tools, placing it in Risk Management Process. The specificity is Domain-Adapted due to the mention of the NIST Framework and specific cybersecurity concepts like vulnerabilities and detection tools.


reasoning: The paragraph explicitly states the company is a blank check company with no operations or cybersecurity processes of its own, meeting the threshold for None/Other. It contains only generic statements about reliance on third parties without any specific cybersecurity details.


fact: CISSP

fact: CISM

fact: CISA

reasoning: The paragraph describes the management team's responsibilities and qualifications regarding cybersecurity, making it Management Role. The mention of specific, verifiable certifications (CISSP, CISM, CISA) elevates the specificity to Quantified-Verifiable.


fact: AB

fact: the Adviser

fact: denial of service attacks

reasoning: The paragraph introduces the company's information security environment and process goals, noting its reliance on its adviser's technology. It is classified as Firm-Specific because it names the specific entities (AB and the Adviser) whose technology the company relies upon.


reasoning: The paragraph describes the board of directors' oversight role and how the executive leadership team reports to the board on cybersecurity risks, fitting the Board Governance category. The language is entirely generic with no domain-specific terminology or firm-specific details.


fact: more than seven years

reasoning: The paragraph primarily details the roles, responsibilities, and experience of management (Deputy CEO and CFO) in leading the cybersecurity program, fitting the Management Role category. It includes a verifiable lower bound of experience ('more than seven years'), elevating the specificity to Quantified-Verifiable.


reasoning: The paragraph describes the use of a third party to assess the company's cybersecurity risk management processes, which falls under Risk Management Process. The language is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph describes the Board's oversight role and delegation to a committee or officer, fitting the Board Governance category. The language is entirely generic and lacks specific domain terms, firm-specific details, or verifiable metrics.


reasoning: The paragraph discusses both the use of third-party consultants for internal risk management and the security requirements imposed on third-party service providers, fitting the Third-Party Risk category. The language relies entirely on generic risk management terminology without specific domain terms or verifiable facts.


fact: Enterprise Risk Management Committee ("ERMC")

fact: TISC

fact: Director of Enterprise Risk Management

fact: Chief Risk Officer

reasoning: The paragraph primarily describes the structure, composition, and leadership of a management-level committee (ERMC) responsible for risk governance, making it Management Role. It includes firm-specific details such as the named ERMC, TISC, and specific management titles (Director of ERM, CRO).


reasoning: The paragraph focuses entirely on the oversight of third-party service providers and vendor risk assessments, placing it in Third-Party Risk. The language used is generic and lacks specific domain terminology, firm-specific details, or verifiable metrics.


specificity_confidence: medium

reasoning: The paragraph explicitly discusses the identification and oversight of cybersecurity risks associated with the company's use of third-party suppliers, vendors, and service providers. It is classified as Firm-Specific because it identifies reliance on a specific entity ('the Adviser') for this oversight.


fact: over 30 years of experience in various information technology roles

fact: over 20 years of experience as an IT Director

fact: over 10 years of experience in risk management

reasoning: The paragraph focuses on the responsibilities and qualifications of management personnel overseeing cybersecurity, placing it in Management Role. It reaches Quantified-Verifiable specificity by providing specific, verifiable lower bounds for the years of experience held by the Global Director of IT and the CFO.


reasoning: The paragraph primarily describes the activities of the risk management program, including evaluating safeguards, testing, and employee training. The language is entirely generic and lacks any domain-specific terminology, firm-specific roles, or verifiable metrics.


reasoning: The paragraph primarily describes the board's oversight structure, detailing the Audit Committee's responsibilities and the reporting chain from management (COO). The specificity is Generic Boilerplate because the titles mentioned (Audit Committee, COO, Director of Information Technology) and processes described do not meet the threshold for firm-specific or domain-adapted facts according to the classification rules.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity incidents on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only generic boilerplate language with no domain-specific terminology, firm-specific details, or verifiable facts.


fact: fourth quarter of fiscal 2025

reasoning: The paragraph describes a specific, actual cybersecurity incident, detailing the containment measures, operational disruption, and financial impact, which aligns with Incident Disclosure. The inclusion of a specific timeframe (fourth quarter of fiscal 2025) for the event makes it Quantified-Verifiable.


reasoning: The paragraph describes the use of third-party consultants to support the company's internal cybersecurity program, which falls under Risk Management Process. The language is entirely generic and lacks specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph is entirely focused on managing cybersecurity risks associated with third-party service providers, including reviewing and updating contracts for security and confidentiality. It contains no domain-specific terminology, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


fact: Chief Privacy Officer

fact: Chief Information Security Officer

fact: Risk Oversight Committee

fact: Information Security Program

fact: Security Incident Response Policy and Plan

fact: over 13 years previously serving as the Company's Chief Financial Officer

fact: over 20 years of work experience in cybersecurity

reasoning: The paragraph primarily describes the roles, responsibilities, and qualifications of management personnel (Chief Privacy Officer, Chief Information Security Officer) in overseeing cybersecurity, making it Management Role. The specificity is Quantified-Verifiable due to the specific, verifiable years of experience provided for both officers.


fact: IT Risk and Compliance Team

fact: VP Security

reasoning: The paragraph primarily describes the organizational structure and reporting lines of management teams responsible for IT controls, specifically the IT Risk and Compliance Team reporting to the VP Security. Specificity is Firm-Specific due to the named internal team and VP-level security role.


reasoning: The paragraph explicitly discusses the processes and procedures established to oversee and identify cybersecurity risks associated with third parties, fitting the Third-Party Risk category. The language used is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable metrics, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph discusses the potential financial impact of cyber risks and includes a negative assertion that the company has not encountered any cybersecurity incidents, which falls under Strategy Integration. The language is entirely generic boilerplate typical of SPACs, lacking any specific domain terminology, firm-specific details, or verifiable facts.


reasoning: The paragraph makes a negative assertion regarding the material impact of cybersecurity incidents on the company, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or externally verifiable facts, making it generic boilerplate.


reasoning: The paragraph explicitly states a conclusion about whether cybersecurity risks or incidents have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which aligns perfectly with the Strategy Integration category. It contains no domain terms, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


fact: Chief Information Officer

fact: cybersecurity governance committee

fact: Chief Financial Officer, Chief Legal Officer, Chief Information Officer, Head of Internal Audit

reasoning: The paragraph focuses entirely on management's organizational structure, detailing the roles of the CIO, the IT team, and the composition of the cybersecurity governance committee. It is classified as Firm-Specific due to the naming of specific management roles and a dedicated internal committee.


reasoning: The paragraph is a fragment of a risk factor header or cross-reference, containing no substantive description of cybersecurity processes, governance, or incidents. It lacks any specific facts or domain terminology, making it generic boilerplate.


fact: Vice President of Information Systems

reasoning: The paragraph primarily describes the governance structure and reporting chain for cybersecurity, detailing how management reports to the Audit Committee and the Board of Trustees. The specificity is Firm-Specific due to the mention of the 'Vice President of Information Systems' leading the program.


fact: January 18, 2023

fact: ransomware

fact: fewer than 300 restaurants

fact: one market for one day

reasoning: The paragraph explicitly describes a past cybersecurity incident (a ransomware attack), detailing its date, scope, and operational impact, which clearly falls under Incident Disclosure. The inclusion of a specific date and quantified operational impacts (fewer than 300 restaurants for one day) makes it Quantified-Verifiable.


reasoning: The paragraph explicitly states a conclusion about the material impact of cybersecurity incidents on the firm's strategy, financial condition, and results of operations, which aligns with the Strategy Integration category. The text contains no domain-specific terminology, firm-specific facts, or externally verifiable claims, making it Generic Boilerplate.


fact: CCO

fact: real time threat detection

reasoning: The paragraph primarily describes management's responsibilities and how they stay informed about cybersecurity, specifically naming the CCO and detailing communication channels with the Investment Advisor's personnel. The specificity is Firm-Specific due to the explicit assignment of cybersecurity responsibilities to the CCO.


reasoning: The paragraph is a pure cross-reference to the Risk Factors section, containing no substantive cybersecurity disclosure.


fact: IT Steering Committee

fact: incident response

fact: attack vectors

fact: vulnerabilities

reasoning: The paragraph primarily describes the company's cybersecurity program, including risk identification, monitoring, mitigation, and integration with enterprise risk management, making it Risk Management Process. The mention of the 'IT Steering Committee' elevates the specificity to Firm-Specific.


reasoning: The paragraph makes a negative assertion regarding the material impact of past cybersecurity incidents, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or externally verifiable facts, making it generic boilerplate.


reasoning: The paragraph focuses entirely on the oversight of third-party service providers, including vendor risk assessments and contractual obligations. The language used is generic and lacks specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's strategy and financial condition, placing it in Strategy Integration. It contains no domain-specific terminology or verifiable facts, making it generic boilerplate.


fact: Enterprise Risk and Compliance Committee (ERC Committee)

reasoning: The paragraph describes the reporting of findings to a specific board committee, indicating Board Governance. The mention of the uniquely named 'Enterprise Risk and Compliance Committee' makes it Firm-Specific.


reasoning: The paragraph explicitly states conclusions regarding the material impact of cybersecurity risks and incidents on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains no specific domain terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph primarily describes the roles and responsibilities of management (Senior Director of IT, CEO, GC, CFO) in implementing and maintaining cybersecurity processes, making it Management Role. The specificity is Firm-Specific due to the mention of the 'Senior Director of Information Technology' role.


reasoning: The paragraph consists entirely of a forward-looking disclaimer and a cross-reference to the Risk Factors section, containing no substantive cybersecurity disclosure.


reasoning: The paragraph focuses entirely on the risks associated with third-party service providers and the company's monitoring of those risks. It contains only generic language without any specific domain terminology, firm-specific details, or verifiable metrics.


fact: Senior Director - Information Security

fact: over 15 years' experience in the information technology and cybersecurity field

fact: over 15 years' experience in auditing information security

fact: CISO Academy Workshop

fact: BA in math and computer science from Ohio Wesleyan University

fact: Information Systems Auditor certification

reasoning: The paragraph focuses entirely on the qualifications, career history, and credentials of the Senior Director - Information Security, which falls squarely under Management Role. It reaches Quantified-Verifiable specificity due to multiple externally verifiable claims, including specific years of experience, a named university degree, and a specific professional certification.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only generic boilerplate language and negative assertions, with no specific facts or domain terminology.


reasoning: The paragraph provides a high-level overview of the company's cybersecurity program and risk assessment activities, placing it in Risk Management Process. The language is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph focuses entirely on the processes used to manage cybersecurity risks associated with third-party service providers. The language used is generic and lacks specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph describes the board of directors' oversight of cybersecurity risks, including the role of the audit committee and executive officers, making it Board Governance. It contains only generic boilerplate language with no domain-specific terminology, firm-specific details, or verifiable metrics.


fact: August 2020

reasoning: The paragraph describes a specific historical cybersecurity incident (August 2020 ransomware attack), including the nature of the attack, the response, and the impact, making it Incident Disclosure. The inclusion of a specific date (August 2020) makes it Quantified-Verifiable.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only generic boilerplate language and negative assertions without any specific domain terminology or verifiable facts.


reasoning: The paragraph explicitly states a conclusion about the material impact of cybersecurity incidents on the company's business strategy and financial condition, aligning with Strategy Integration. The language is entirely generic with no domain-specific terminology, firm-specific details, or verifiable facts.


fact: CISO

fact: FedEx Executive Committee

fact: DTRC

fact: CyTOC

fact: threat intelligence briefings

reasoning: The paragraph primarily describes management's organizational structure, reporting lines (CISO to CEO), and the specific management committees involved in cybersecurity oversight and incident communication. The specificity is Firm-Specific due to the inclusion of the CISO role and uniquely named internal committees like the DTRC and CyTOC.


fact: Corporate Controller

fact: Vice President of Information Technology

fact: phishing and penetration tests

reasoning: The paragraph describes the risk management process, including the involvement of specific roles and the use of third-party phishing and penetration tests. The mention of specific years (2023, 2024) makes it Quantified-Verifiable.


reasoning: The paragraph makes a negative assertion regarding the absence of material cybersecurity incidents, which classifies it as Strategy Integration. The text contains only generic risk disclaimers and reporting-period anchors without any domain-specific terminology, firm-specific details, or verifiable facts.


reasoning: The paragraph focuses exclusively on the oversight and management of cybersecurity risks associated with third-party service providers, including assessments and contractual provisions. The specificity is Domain-Adapted due to the reference to a specific third-party information risk management program.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, aligning with the Strategy Integration category. It contains only generic SEC boilerplate language and cross-references, lacking any specific domain terms, firm-specific details, or verifiable facts.


fact: ransomware

fact: malicious computer viruses

fact: AI and machine-learning technologies

reasoning: The paragraph describes the company's technology infrastructure, the types of cybersecurity threats it faces (ransomware, viruses, AI-driven threats), and the potential impact on confidentiality, integrity, or availability, which aligns with Risk Management Process. The specificity is Domain-Adapted due to the use of cybersecurity-specific terminology like 'ransomware' and 'confidentiality, integrity, or availability' (CIA triad).


reasoning: The paragraph describes the company's general methodology for conducting cybersecurity risk assessments, placing it in the Risk Management Process category. The language used consists entirely of generic enterprise risk management terminology without any domain-specific cybersecurity terms, firm-specific details, or verifiable metrics.


fact: CISSP (Certified Information Systems Security Professional)

fact: CCSP (Certified Cloud Security Professional)

fact: penetration testing

fact: vulnerability scanning

fact: intrusion detection

reasoning: Although the paragraph begins by detailing the qualifications of the Director of Information Security and Privacy, the majority of the text describes the specific activities and tools used in the risk management process. The specificity is Quantified-Verifiable because it lists externally verifiable certifications (CISSP, CCSP) held by the director.


reasoning: The paragraph describes high-level procedures for asset identification and classification within the cybersecurity risk management program, which falls under Risk Management Process. The language is generic and lacks specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph explicitly states a conclusion about the material impact of cybersecurity risks on the company's business strategy and financial condition, placing it in Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable metrics, resulting in a Generic Boilerplate specificity.


fact: June 2024

fact: CDK

reasoning: The paragraph primarily describes a specific historical cybersecurity incident (the June 2024 CDK breach), its operational impact, and how it triggered the company's response plan, making it Incident Disclosure. Specificity is Quantified-Verifiable due to the inclusion of a specific date and a named third-party provider.


reasoning: The paragraph is entirely focused on the process for managing cybersecurity risks associated with third-party service providers, making it a clear fit for Third-Party Risk. The language used is generic and lacks any domain-specific terminology, firm-specific details, or verifiable facts, resulting in a Generic Boilerplate specificity level.


fact: Technology Committee

reasoning: The paragraph explicitly describes the Board's oversight of cybersecurity risks and its delegation of this responsibility to the Technology Committee, placing it squarely in Board Governance. The mention of the specific 'Technology Committee' elevates the specificity to Firm-Specific.


fact: scanning our environment for vulnerabilities

reasoning: The paragraph describes the activities of the cybersecurity risk management program, including vulnerability scanning and penetration testing, which categorizes it as Risk Management Process. The specificity is Domain-Adapted due to the use of cybersecurity-specific terminology like penetration testing.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, placing it in Strategy Integration. It contains only generic boilerplate language and negative assertions without any specific domain terms, firm-specific details, or verifiable facts.


fact: CSIRPs (Cyber Security Incident Response Plans)

reasoning: The paragraph describes the components and phases of the company's incident response plans, which is a core part of the Risk Management Process. The listing of specific incident response lifecycle phases (detection, analysis, containment, eradication, recovery) demonstrates domain-adapted cybersecurity expertise.


fact: Cybersecurity Program Manager

reasoning: The paragraph is entirely focused on managing cybersecurity risks associated with third-party service providers and vendors, making it Third-Party Risk. The mention of the 'Cybersecurity Program Manager' elevates the specificity to Firm-Specific.


fact: Technology Steering Committee

reasoning: The paragraph describes the oversight structure for cybersecurity risk management, focusing on the board and its committees, making it Board Governance. It includes the firm-specific 'Technology Steering Committee'.


reasoning: The paragraph makes a negative assertion regarding the material impact of past cybersecurity threats, which classifies it as Strategy Integration. It contains no domain-specific terminology, firm-specific details, or externally verifiable facts, making it generic boilerplate.


reasoning: The paragraph describes the audit committee's oversight of the cybersecurity risk management program, its reporting to the board, and updates received from the CFO, making it clearly Board Governance. It contains no domain-specific terms, firm-specific roles (CFO and audit committee are generic), or verifiable facts, resulting in Generic Boilerplate specificity.


fact: Audit and Finance Committee

fact: CIO

fact: management committee on cybersecurity

reasoning: The paragraph primarily describes how management briefs the board and its committees on cybersecurity risks, making it Board Governance. The specificity is Firm-Specific due to the mention of specific roles like the Senior Director, Information Protection & Compliance, the CIO, and a management committee on cybersecurity.


fact: CISO

fact: Security Steering Committee

fact: CTO

fact: CSIRT

fact: PSIRT

reasoning: The paragraph primarily describes the roles, responsibilities, and reporting structure of management (CISO, Security Steering Committee, CSIRT, PSIRT) regarding cybersecurity oversight, fitting the Management Role category. The specificity is Firm-Specific due to the naming of specific internal committees and teams (Security Steering Committee, CSIRT, PSIRT) and executive roles (CISO, CTO).


fact: threat assessments

fact: proactive detection tools

reasoning: The paragraph describes the company's risk management activities, including the use of external experts for threat assessments and the deployment of proactive detection tools. The specificity is Domain-Adapted due to the use of cybersecurity-specific terminology like threat assessments and proactive detection tools, without any firm-specific or verifiable details.


reasoning: The paragraph discusses general regulatory requirements and SEC disclosure rules, ending with a cross-reference, containing no substantive cybersecurity program details. As a None/Other paragraph, it defaults to Generic Boilerplate.


reasoning: The paragraph explicitly discusses the Board of Directors' oversight responsibilities regarding cybersecurity risks, placing it in Board Governance. The language is entirely generic boilerplate with no specific domain terms, firm-specific details, or verifiable facts.


reasoning: The paragraph is a standard forward-looking statements disclaimer and contains no substantive cybersecurity disclosure, making it None/Other with Generic Boilerplate specificity.


fact: Vants

reasoning: The paragraph focuses on the responsibilities and qualifications of the CISO, placing it in the Management Role category. Specificity is Firm-Specific due to the mention of the CISO role and the company-specific term 'Vants'.


fact: third-party risk monitoring security rating services

reasoning: The paragraph focuses exclusively on managing cybersecurity risks associated with third parties, including diligence and contractual protections. It includes domain-specific terminology like 'security rating services' but lacks firm-specific or verifiable details.


reasoning: The paragraph describes standard risk management activities, specifically incident response planning and employee training, using generic terminology without demonstrating specialized domain expertise or firm-specific details.


fact: phishing attack

reasoning: The paragraph describes a specific cybersecurity incident (a phishing attack resulting in an incorrect payment), including the timeline, financial impact, recovery, and remediation, making it Incident Disclosure. The specificity is Quantified-Verifiable due to the inclusion of specific dates (April 28, 2023; June 29, 2023) and a specific dollar amount ($54,300).


fact: December 2022

fact: cybersecurity threat to its information technology system

fact: personal data of employees, had been extracted

fact: containment protocols

fact: forensics experts

reasoning: The paragraph describes a specific cybersecurity incident that occurred in December 2022, including the extraction of employee data and the company's response, making it an Incident Disclosure. The specificity is Quantified-Verifiable due to the specific date (December 2022) tied to a real event.


reasoning: The paragraph serves as an introductory statement regarding the company's general approach to identifying and mitigating cybersecurity threats, falling under risk management processes, but contains only generic boilerplate language.


reasoning: The paragraph is a generic cross-reference to the Risk Factors section and contains speculative boilerplate about potential material effects, lacking substantive cybersecurity disclosure.


fact: February and April 2025

fact: Microsoft

fact: Azure environment

fact: nation-state threat actor

fact: rotation of credentials

reasoning: The paragraph primarily describes a specific cybersecurity incident involving unauthorized activity in the company's Azure environment, including the timeline (February and April 2025) and response actions. The presence of specific dates, a named third-party firm (Microsoft), and a named system (Azure) makes it Quantified-Verifiable.


fact: fiscal 2023

fact: Fortra, LLC

fact: GoAnywhere managed file transfer as a service system (MFTaaS)

fact: zero-day vulnerability

fact: Health Insurance Portability and Accountability Act

reasoning: The paragraph describes a specific cybersecurity incident involving a third-party vendor (Fortra), detailing the nature of the incident, the systems affected, the type of data compromised, and the company's response. The specificity is Quantified-Verifiable due to the naming of the specific third-party vendor (Fortra, LLC), the specific system (GoAnywhere), and the timeframe (fiscal 2023).


fact: penetration testing

fact: forensic analysis

fact: NIST framework

fact: Global Corporate Continuity Program

reasoning: The paragraph primarily discusses how the company manages cybersecurity risks presented by third parties, including vendors and service providers, making it Third-Party Risk. The specificity is Firm-Specific due to the mention of the named internal program 'Global Corporate Continuity Program'.


reasoning: The paragraph discusses general regulatory requirements (SEC rules and banking agency oversight) and provides a cross-reference to another section of the filing, containing no substantive cybersecurity program disclosures. Per the rules, None/Other paragraphs are assigned Generic Boilerplate specificity.


reasoning: The paragraph consists entirely of generic speculative statements about potential cyber risks and a cross-reference to the Risk Factors section, containing no substantive disclosure of the company's actual cybersecurity program.


reasoning: The paragraph focuses exclusively on the oversight of vendor cybersecurity risks, placing it in Third-Party Risk. The language used is generic and lacks specific domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph describes the reporting structure for material cybersecurity matters from senior management to the Audit Committee, which falls under Board Governance. It contains only generic terms and standard committee names, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph makes a negative assertion regarding the material impact of cybersecurity incidents, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or externally verifiable cybersecurity facts, making it generic boilerplate.


fact: Information Security Officer

fact: Chief Information Officer

reasoning: The paragraph focuses on the responsibilities of specific management roles (Information Security Officer and Chief Information Officer) regarding mandatory training, placing it in Management Role. Specificity is Firm-Specific due to the explicit naming of these executive IT and security titles.


fact: threat actors

fact: phishing attempt

fact: phishing security test

reasoning: The paragraph describes the company's employee training and phishing simulation activities, which are core components of its risk management process. The specificity is Domain-Adapted due to the use of cybersecurity-specific terms like 'phishing attempt' and 'threat actors'.


reasoning: The paragraph explicitly states a conclusion about whether cybersecurity risks have materially affected or are reasonably likely to materially affect the company's business strategy, results of operations, or financial condition, which falls squarely under Strategy Integration. It contains no domain terms, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, which falls under Strategy Integration. It contains only generic boilerplate language and negative assertions without any specific facts.


fact: categorized into tiers

fact: Vendor due diligence questionnaires

fact: vendor incident response procedures

reasoning: The paragraph focuses entirely on the oversight and assessment of third-party service providers and vendors. It includes domain-specific terminology such as vendor tiering and due diligence questionnaires, but lacks firm-specific or externally verifiable details.


fact: privileged access policies

fact: multi-factor authentication

reasoning: The paragraph primarily describes security measures implemented (privileged access policies, multi-factor authentication), which falls under Risk Management Process. The specificity is Domain-Adapted due to the use of cybersecurity-specific terminology.


reasoning: The paragraph consists entirely of hypothetical risk statements and boilerplate language about potential impacts of cybersecurity incidents, without describing any actual cybersecurity program, governance, or strategy.


fact: $14.3 million of costs

reasoning: The paragraph primarily describes a specific cybersecurity incident that occurred on July 23, 2023, including its financial impact and the conclusion of the investigation, making it Incident Disclosure. The specificity is Quantified-Verifiable due to the specific date and the exact dollar amount of costs incurred.


reasoning: The paragraph is a pure cross-reference to the Risk Factors section in Item 1A, containing no substantive cybersecurity disclosures.


fact: System and Organizational Control ("SOC") type reports

reasoning: The paragraph describes the company's cybersecurity program activities, including software deployment, internal audits, and vendor requirements, making it primarily about the Risk Management Process. Specificity is Domain-Adapted due to the specific mention of SOC reports.


fact: external and internal penetration testing

fact: remediate identified vulnerabilities

reasoning: The paragraph is a mixed disclosure covering penetration testing, third-party risk management, and cyber insurance, but the largest portion of the text is dedicated to detailing the processes for overseeing third-party service providers. The specificity is Domain-Adapted due to the use of cybersecurity-specific terms like penetration testing and vulnerability remediation.


reasoning: The paragraph explicitly states the company is a SPAC with no operations and has not adopted a cybersecurity program, falling under the None/Other category. It contains no specific cybersecurity facts or domain terminology, resulting in Generic Boilerplate specificity.


fact: Chief Financial Officer ("CFO")

fact: CCO

fact: CFO has been responsible for his oversight function as CFO to the Company for three years

fact: worked in the financial services industry for more than 30 years

fact: CCO has been responsible for oversight functions for the Company for three years

fact: current CCO has been serving since April 2025

fact: worked in the financial services industry for more than 35 years

reasoning: The paragraph explicitly details management's role in cybersecurity risk management, focusing on the responsibilities, tenure, and experience of the CFO and CCO. The specificity is Quantified-Verifiable due to the inclusion of specific dates (April 2025) and verifiable years of experience (three years, more than 30 years, more than 35 years).


fact: Chief Information Officer

reasoning: The paragraph is entirely focused on how the company oversees and manages cybersecurity risks associated with third-party service providers, making it Third-Party Risk. The specificity is Firm-Specific due to the mention of the Chief Information Officer.


reasoning: The paragraph consists entirely of a generic statement about cybersecurity risks and a cross-reference to the Risk Factors section, containing no substantive cybersecurity disclosures.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks and incidents on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


reasoning: The paragraph explicitly details the company's processes for overseeing and assessing security risks related to third-party vendors and technology, making it a clear fit for Third-Party Risk. The language used is entirely generic, lacking any specific domain terminology, firm-specific details, or verifiable metrics, resulting in a Generic Boilerplate specificity level.


reasoning: The paragraph explicitly discusses overseeing and managing risks associated with third-party service providers, making it a clear fit for Third-Party Risk. The language used is generic and lacks any domain-specific terminology, firm-specific details, or verifiable facts, resulting in a Generic Boilerplate specificity level.


reasoning: The paragraph focuses exclusively on the oversight of third-party service providers and contractual security requirements, placing it in Third-Party Risk. The language is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable metrics.


fact: Chief Information Security Officer (CISO)

fact: Chief Information Officer (CIO)

fact: over 30 years of experience

fact: Department of Defense

fact: CIO Program Certificate from the College of Information and Cyberspace, National Defense University

fact: Certified Information System Security Professional (CISSP)

fact: Certified Information Privacy Professional (CIPP)

reasoning: The paragraph is classified as Management Role because it details the organizational structure of the cybersecurity team, reporting lines (CISO to CIO), and the specific qualifications of the CISO. The specificity is Quantified-Verifiable due to the inclusion of verifiable facts such as 'over 30 years of experience', specific past employers (Department of Defense), and verifiable certifications (CISSP, CIPP, National Defense University certificate).


fact: IT Lead

fact: 5 years of experience

fact: about 15 years of expertise

reasoning: The paragraph focuses on the roles, responsibilities, and qualifications of management (specifically the IT Lead) in overseeing cybersecurity. It includes verifiable quantified facts regarding the years of experience of both the IT Lead and the external agency.


reasoning: The paragraph explicitly states the company is a SPAC with no operations and no cybersecurity program, which falls under the None/Other category per the rules. The language is entirely generic boilerplate with no specific cybersecurity facts or domain terminology.


reasoning: The paragraph lists oversight and promotional responsibilities regarding cybersecurity policies, which typically describes board or committee governance duties. The language used is entirely generic and lacks any specific domain terminology or firm-specific details.


fact: Audit Review Committee (ARC)

reasoning: The paragraph primarily describes the Board's oversight of cybersecurity risks and its delegation of these responsibilities to a specific committee. The specificity is Firm-Specific due to the distinct naming of the 'Audit Review Committee (ARC)' rather than a generic audit committee.


fact: Information Technology Committee

reasoning: The paragraph primarily describes the Board's oversight of the cybersecurity program, including reporting cadences and approval responsibilities. It is Firm-Specific because it names the internal Information Technology Committee.


fact: CIO firms

fact: managed service provider

reasoning: The paragraph explicitly details the company's processes for overseeing third-party service providers, including due diligence and continuous monitoring. The mention of specific outsourced 'CIO firms' elevates the specificity to Firm-Specific.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity risks on the company's business strategy and financial condition, aligning with Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable metrics, making it generic boilerplate.


fact: 24x7 Security Operations Center (SOC)

fact: Security Information and Event Management (SIEM)

reasoning: The paragraph describes the tools and operations used in the company's cybersecurity program, categorizing it as Risk Management Process. It includes domain terms like SIEM and a firm-specific operational claim of maintaining a 24x7 SOC.


fact: Vendor Management Program

fact: CCDC

reasoning: The paragraph focuses entirely on the oversight of cybersecurity risks related to vendors and suppliers, making it Third-Party Risk. Specificity is Firm-Specific due to the mention of the internal CCDC and the formal Vendor Management Program.


reasoning: The paragraph primarily describes the flow of cybersecurity information from management to the Board of Directors and the Board's oversight activities, placing it in Board Governance. It lacks domain-specific terminology, firm-specific roles (Director of IT is explicitly excluded by the prompt rules), or verifiable facts, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph describes the Board of Directors' and Audit Committee's oversight of the enterprise risk management program and cybersecurity risks, including updates from the CFO, which clearly falls under Board Governance. The language is generic and lacks domain-specific terminology, firm-specific roles (CFO and Audit Committee are generic), or verifiable facts, resulting in a Generic Boilerplate specificity.


reasoning: The paragraph describes the Audit Committee's responsibility to report cybersecurity risks to the Board of Directors and the Board's annual review of these risks, which clearly falls under Board Governance. The language is generic and lacks any domain-specific terminology, firm-specific details, or verifiable facts, resulting in a Generic Boilerplate specificity level.


reasoning: The paragraph focuses entirely on the risks associated with third-party service providers and the company's vendor management process. The language used is highly generic and lacks specific cybersecurity domain terminology, firm-specific details, or verifiable metrics.


reasoning: The paragraph is a pure cross-reference to the Risk Factors section and contains no substantive cybersecurity disclosures, making it None/Other with Generic Boilerplate specificity.


reasoning: The paragraph explicitly states the company is a blank check company with no operations or cybersecurity program, which falls under the None/Other category for SPACs. It contains no specific cybersecurity facts or domain terminology.


reasoning: The paragraph explicitly states a conclusion about the material impact of cybersecurity incidents on the company's business strategy, results of operations, and financial condition, which aligns with the Strategy Integration category. It contains no domain terms, firm-specific facts, or verifiable claims, making it Generic Boilerplate.


reasoning: The paragraph focuses exclusively on the oversight and monitoring of third-party providers' cybersecurity. It uses generic language without any specific domain terms, firm-specific details, or verifiable metrics.


fact: malware detection

fact: phishing simulations

reasoning: The paragraph describes the company's security awareness program and employee training activities, which falls under Risk Management Process. It includes domain-specific terminology like 'malware detection' and 'phishing simulations', making it Domain-Adapted.


reasoning: The paragraph focuses entirely on the oversight of third-party risks and business partners' cybersecurity practices. It lacks any specific domain terminology, firm-specific details, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph explicitly describes the company's third-party vendor management program and how it oversees cybersecurity risks presented by vendors. The language is high-level and lacks specific cybersecurity domain terminology, firm-specific details, or verifiable metrics, making it generic boilerplate.


reasoning: The paragraph explicitly states the company is a SPAC with no operations and no cybersecurity program, meeting the threshold for None/Other. It contains no domain terminology or specific facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph explicitly states a conclusion regarding the material impact of cybersecurity threats on the company's business strategy and financial condition, placing it in Strategy Integration. The language consists entirely of generic boilerplate and standard SEC phrasing without any specific domain terms or verifiable facts.


fact: Sphere 3D Corp.

fact: 26 BTC

fact: approximately $560,000

fact: US Federal law enforcement

reasoning: The paragraph describes a specific, actual cybersecurity incident involving a threat actor impersonating a CFO and stealing 26 BTC, making it Incident Disclosure. The specificity is Quantified-Verifiable due to the inclusion of specific dates, named external entities (Sphere 3D Corp., US Federal law enforcement), and quantified financial impacts (26 BTC, $560,000).


reasoning: The paragraph is a generic introductory statement acknowledging cybersecurity risks and potential impacts, containing no substantive disclosure about the company's actual cybersecurity program, governance, or strategy.


reasoning: The paragraph explicitly states conclusions about the lack of material impact on business strategy and financial condition from cybersecurity threats, which falls under Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, making it generic boilerplate.


fact: Chief Information Officer ("CIO")

fact: Chief Information Security Officer ("CISO")

fact: over 20 years of experience

reasoning: The paragraph describes the cybersecurity oversight chain, detailing management roles (CIO, CISO) and their reporting to the Audit Committee, making it primarily about Board Governance and oversight structure. The specificity is Quantified-Verifiable because it states the CIO and CISO have over 20 years of experience, which is an externally verifiable claim.


reasoning: The paragraph provides general background information about the company's IT systems and data collection without describing any substantive cybersecurity measures, processes, or governance.


fact: SOC reports

fact: complementary controls

reasoning: The paragraph primarily details the processes for overseeing and managing risks associated with third-party service providers, making it Third-Party Risk. Specificity is Domain-Adapted due to the mention of cybersecurity-specific concepts like SOC reports and complementary controls.


reasoning: The paragraph describes the use of third-party consultants and service providers to support the company's internal risk management and security processes, which falls under Risk Management Process. The language is entirely generic and lacks specific domain terminology, firm-specific details, or verifiable facts.


fact: confidentiality, integrity, or availability

reasoning: The paragraph merely provides a standard regulatory definition of 'cybersecurity threat' without describing any actual company processes, governance, or strategy, placing it in None/Other. It uses domain terminology (the CIA triad) adapted from regulatory definitions.


reasoning: The paragraph describes the integration of the cybersecurity program into the broader enterprise risk management framework and outlines general risk management activities, fitting the Risk Management Process category. The language relies entirely on generic boilerplate terms without any specific domain terminology, firm-specific roles, or verifiable facts.


reasoning: The paragraph provides a high-level overview of the company's processes to identify and manage cybersecurity risks to its systems and data, fitting the Risk Management Process category. It lacks any specific cybersecurity domain terminology, firm-specific details, or verifiable metrics, making it generic boilerplate.


fact: system scans

fact: threat intelligence analysis

reasoning: The paragraph primarily describes the company's risk management activities, including employee training and the use of third parties for system scans and threat intelligence. It is classified as Domain-Adapted due to the use of cybersecurity-specific terminology like 'threat intelligence analysis'.


fact: nation-state and nation-state supported actors

reasoning: The paragraph provides generic introductory context about the company's reliance on IT systems and the general threat landscape without detailing any specific cybersecurity measures, governance, or incidents. It includes domain terminology regarding specific threat actor types.


fact: identify and detect threats

fact: response or recovery situation

reasoning: The paragraph describes the Audit Committee's oversight of the cybersecurity program, placing it in Board Governance. The specificity is Domain-Adapted due to the use of cybersecurity-specific terminology like 'detect threats' and 'response or recovery'.


reasoning: The paragraph explicitly describes the process for assessing data protection practices of third-party vendors, making it Third-Party Risk. The language is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable facts.


reasoning: The paragraph explicitly states the company is a blank check company with no operations or cybersecurity processes of its own, meeting the threshold for None/Other. It contains no specific cybersecurity facts or domain terminology.


reasoning: The paragraph is a generic introductory statement about the types of data the company collects and does not describe any substantive cybersecurity measures, governance, or strategy.


fact: MIS consultant

fact: MIS supervisor

reasoning: The paragraph describes management's role in overseeing cybersecurity, specifically detailing the responsibilities and reporting lines of the MIS consultant and MIS supervisor to the CEO. The specificity is Firm-Specific due to the naming of specific management roles (MIS consultant, MIS supervisor).


reasoning: The paragraph explicitly states a conclusion about the material impact of past cybersecurity incidents on the company's business strategy and financial condition, placing it in Strategy Integration. It contains no domain-specific terminology, firm-specific details, or verifiable facts, resulting in Generic Boilerplate specificity.


reasoning: The paragraph explicitly focuses on the oversight of cybersecurity risks presented by third parties, including vendors and CROs. The language is generic and lacks specific cybersecurity domain terminology or verifiable facts.


fact: insider threat controls

fact: prevent data loss

reasoning: The paragraph describes specific security measures and controls used to mitigate insider threats and prevent data loss, which falls under the risk management process. The specificity is Domain-Adapted due to the use of cybersecurity concepts like insider threat controls and data loss prevention.


fact: multiple decades of experience

fact: CTO

fact: CISO

fact: internal working group

reasoning: The paragraph describes the qualifications, experience, and roles of management personnel (CTO, CISO, internal working group), fitting the Management Role category. Specificity is Quantified-Verifiable due to the verifiable claim of 'multiple decades of experience'.


fact: DSCP

fact: Form 8-K filed on February 29, 2024

fact: MOVEit Cybersecurity Incident

fact: PBI

fact: 2.5 million to 2.7 million

reasoning: The paragraph primarily details a specific historical cybersecurity event (the MOVEit incident), describing its scope, investigation, and impact, making it an Incident Disclosure. The specificity is Quantified-Verifiable due to the inclusion of hard numbers (2.5 to 2.7 million), specific dates (February 29, 2024), and named third parties (PBI).


reasoning: The paragraph explicitly states a conclusion about the lack of material impact from cybersecurity incidents on the company's business strategy and financial condition, fitting the Strategy Integration category. It contains only generic risk disclaimers and negative assertions without any domain-specific, firm-specific, or verifiable facts.


reasoning: The paragraph primarily describes the reporting chain for cybersecurity incidents and program status, detailing how information flows from the internal team to management, the Audit Committee, and the Board of Directors. It contains only generic governance and monitoring language without specific domain terms or firm-unique details.


reasoning: The paragraph explicitly describes the delegation of cybersecurity risk oversight from the Board of Directors to the Audit Committee, placing it squarely in Board Governance. The language is entirely generic and lacks any domain-specific terminology, firm-specific details, or verifiable metrics.


fact: Chief Information Officer (CIO)

fact: more than 20 years of experience

fact: operational technology

reasoning: The paragraph primarily describes management's role by detailing the CIO's responsibilities and qualifications. The specificity is Quantified-Verifiable due to the verifiable claim of the CIO having more than 20 years of experience.


reasoning: The paragraph explicitly states the company has no cybersecurity personnel or processes of its own, which aligns with the rule to classify SPACs and no-operations companies with no program as None/Other. It contains no domain-specific terminology or firm-specific facts.


fact: vulnerability management

reasoning: The paragraph describes the reporting structure and oversight of cybersecurity, specifically management's updates to the Audit Committee, placing it in Board Governance. The specificity is Domain-Adapted due to the inclusion of the cybersecurity-specific term 'vulnerability management'.