reasoning: The paragraph describes the company's internal cybersecurity processes — incident response planning, cross-functional coordination, escalation controls, and disclosure procedures. While the Audit Committee and SVP Administration are mentioned, the primary content is about what the processes do, not about the people or board oversight. The specific departmental composition (technology, operations, legal, risk management) and the named Incident Response Committee chaired by the SVP Administration are firm-specific organizational details, but there are not two hard verifiable facts (no dates, dollar amounts, named third-party firms, or tools) to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph from Greenbrier Companies (GBX) 10-K Item 1C filing.

The paragraph describes two aspects:
1. Incident Response and Recovery Planning - established IR plan, tested periodically
2. Communication, Coordination and Disclosure - cross-functional approach, escalation controls, Incident Response Committee chaired by SVP Administration

Primary content: This is about the company's internal cybersecurity processes - IR planning, cross-functional coordination, escalation procedures. The Audit Committee mention is incidental. The SVP Administration chairing the Incident Response Committee is mentioned but the paragraph is about processes, not the person.

Now I'm evaluating what qualifies as a specific risk management process. The Incident Response Committee is a named program, though generic in title, and it's led by SVP Administration—not a cybersecurity-specific executive role. The key detail here is the cross-functional team structure spanning technology, operations, legal, risk management and other business functions, which indicates a defined organizational approach to incident response. The departmental composition across technology, operations, legal, and risk management is the firm-specific detail here. The Incident Response Committee itself is somewhat generic as a program name, and SVP Administration isn't a cybersecurity-specific title, so the organizational structure doesn't add much beyond that cross-functional team composition. This lands at Firm-Specific level with no QV support since there are no hard verifiable facts like dates, dollar amounts, named firms, tools, headcounts, or certifications.

fact: Cross-functional team comprising technology, operations, legal, risk management and other key business functions


content_category: Risk Management Process

category_confidence: high

specificity_confidence: high

reasoning: The paragraph primarily describes internal risk management activities — evaluating, redesigning, implementing, and maintaining safeguards to mitigate identified risks and address gaps. The brief mention of IT leadership reporting to the CEO is a subordinate detail about reporting structure, not the primary content. Applying the person-vs-function test: the paragraph is about what the company does (process), not about who the person is. No specific facts from the IS list are present — 'IT leadership' is a generic title (not a cybersecurity-specific role like CISO) and 'CEO' is generic C-suite, so specificity remains Generic Boilerplate.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Classify this paragraph.

Content: Describes evaluating and implementing safeguards after risk assessments, with IT leadership reporting to CEO.

Category: This is about internal processes (re-design, implement, maintain safeguards, mitigate risks, address gaps). The IT leadership reporting line is mentioned but is secondary. The primary content is about the risk management process. "IT leadership" is generic, not a cybersecurity-specific title. CEO is generic C-suite.

Specificity: No named frameworks, no specific facts from the IS list. "IT leadership" is generic. "CEO" is generic C-suite. No dates, no numbers, no named tools.

So this falls into generic boilerplate—it's describing standard risk management activities without any concrete details or specialized terminology.


content_category: None/Other

reasoning: This is a SPAC explicitly stating it has no business operations, no cybersecurity risk management program, and no formal processes. Per the codebook's SPAC rule, the absence of a program is not a description of a program, and the perfunctory board mention ('generally responsible... if any') is not substantive governance disclosure. None/Other always receives Generic Boilerplate.

thinking: SPAC with no operations, explicitly states no program.


content_category: Strategy Integration

reasoning: The paragraph makes an explicit materiality assessment ('have not experienced any material cybersecurity threats or incidents'), which per Rule 6 classifies as Strategy Integration even when boilerplate. The forward-looking caveat is secondary. No named entities, dates, frameworks, or firm-specific facts are present.

thinking:
Classify this paragraph.

This is a materiality assessment combined with a forward-looking disclaimer. The key phrase is "have not experienced any material cybersecurity threats or incidents" - this is a materiality conclusion about cybersecurity's impact. Per Rule 6 and the codebook, materiality assessments → Strategy Integration.

Specificity: No named standards, no firm-specific facts, pure boilerplate language. → Generic Boilerplate.


content_category: Incident Disclosure

reasoning: The paragraph describes an actual business email compromise (BEC) incident: a threat actor impersonated a CFO, redirected a BTC transfer, and 26 BTC (~$560,000) was stolen. This is a detailed incident narrative with timeline, attack vector, impact, and recovery outcome. Multiple QV-eligible hard facts are present: specific dollar amount ($560,000), specific quantity (26 BTC), and named third-party firms (Sphere 3D, Gryphon).

thinking:
Classify this paragraph.

This describes an actual cybersecurity incident - a business email compromise (BEC) attack where a threat actor impersonated a CFO and stole 26 BTC (~$560,000).

Content category: Incident Disclosure - describes what happened, the attack vector, the outcome, and recovery attempts.

Specific facts:
- Named firm: Sphere 3D (third-party firm involved)
- Quantified: 26 BTC
- Quantified: ~$560,000
- Named firm: Gryphon (the company's prior name)

Multiple hard verifiable facts: 26 BTC, $560,000, named firms (Sphere 3D). That's well over 2 QV-eligible facts.

This clearly qualifies as Quantified-Verifiable content given the concrete figures and named organizations involved.

fact: Sphere 3D (named third-party firm involved in the incident)

fact: 26 BTC transferred to threat actor

type: quantified

fact: approximately $560,000 value at the time

fact: Gryphon (company's prior/related name that engaged law enforcement)


category_confidence: medium

reasoning: The paragraph contains an explicit materiality assessment ('prior cybersecurity incidents have not had a material adverse effect on our business, financial condition, results of operations, or cash flows'), which per Rule 6 triggers Strategy Integration. While it also touches on generic risk management processes and a cross-reference, the materiality conclusion is the core substantive claim. No named frameworks, roles, tools, dates, or other specific facts appear — all language is generic boilerplate.

thinking:
Let me analyze this paragraph.

Content: Mix of risk acknowledgment, materiality assessment, process description, and cross-reference.

Key elements:
- Generic risk statement about cybersecurity threats
- Materiality assessment: "prior cybersecurity incidents have not had a material adverse effect on our business, financial condition, results of operations, or cash flows"
- Some process mentions (detect, investigate, incident response plan, risk assessment process)
- Cross-reference to Risk Factors

The paragraph contains an explicit materiality assessment ("have not had a material adverse effect"). Per Rule 6, this makes it Strategy Integration.

The dominant purpose: The paragraph opens with risk language, includes a materiality conclusion, mentions some generic processes, and closes with a cross-reference.

The materiality assessment is the substantive anchor here, though the process language around the cybersecurity risk assessment and incident response plan is boilerplate—no specific frameworks, dates, roles, or tools mentioned. This confirms Strategy Integration with Generic Boilerplate characteristics.


reasoning: The paragraph describes the aftermath and response to a cybersecurity incident (stolen BTC): forensic analysis findings, insurance claims, control modifications, and a specific remediation payment. While it includes financial impact ($560,000) and insurance elements that touch Strategy Integration, the dominant content is incident narrative — what happened, what the forensic analysis revealed, and what remediation steps were taken. Two QV-eligible hard facts: specific date (quarter ended June 30, 2023) and dollar amount ($560,000).

thinking:
Let me analyze this paragraph from American Bitcoin Corp.'s 10-K filing, Item 1C.

Content: Describes aftermath of a cybersecurity incident - stolen BTC, forensic analysis, insurance claim, payment of $560,000, modified controls.

Category: This describes what happened in an incident (forensic analysis, threat actor details, response actions) AND financial impact ($560,000 payment, insurance). The dominant content is incident narrative - describing the forensic findings, the response, and remediation. The financial details ($560,000) are part of the incident story. → Incident Disclosure

Now I'm checking the specificity of the facts here. I can identify the quarter ended June 30, 2023 and the $560,000 payment as concrete, verifiable data points. Sphere 3D appears to be a business partner rather than a cybersecurity firm, and while "nationally recognized third-party firm" is mentioned, it's not named specifically. That gives me two quantified-verifiable facts to work with.

fact: Quarter ended June 30, 2023

fact: $560,000 payment to Sphere 3D


content_category: Board Governance

reasoning: The paragraph's primary frame is the board's oversight structure: the board has delegated cybersecurity oversight to a subsidiary's Information Security Committee, which reports back to the board. The board is the grammatical subject establishing the governance arrangement, making this Board Governance rather than Management Role. The named non-generic committee (Information Security Committee) and named individual (Mr. Tao Guolin) are firm-specific facts, but neither qualifies as QV-eligible (named individuals and committees don't count toward the two-fact QV threshold).

thinking:
Let me analyze this paragraph carefully.

Content: The paragraph discusses board delegation of cybersecurity oversight to a subsidiary's Information Security Committee, headed by the CEO. It mentions the committee providing updates to the board.

Category analysis:
- Board delegates oversight → Board Governance signal
- Information Security Committee headed by CEO → could be Management Role
- The primary frame is about the board's oversight structure (delegation pattern), with the committee and CEO as subordinate details
- The grammatical subject starts with "Our board of directors" and the paragraph describes the governance structure

This is Board Governance - the paragraph describes the board's oversight arrangement (delegation to a committee).

Specificity analysis:

Looking at what qualifies as firm-specific, I see the Information Security Committee is a named non-generic committee, and Mr. Tao Guolin is a named individual. For QV eligibility though, I need to check against the specific list—named individuals, named committees, and other details like dates or certifications. The CEO title is generic, the PRC subsidiary reference lacks specificity, and "occasional updates" is too vague. The named committee and individual are present, but I'm checking whether these meet the QV threshold for what counts as quantifiable or sufficiently specific facts.

fact: Information Security Committee

fact: Mr. Tao Guolin (CEO, head of committee)


reasoning: This is a pure cross-reference to Item 1A Risk Factors with no materiality assessment or substantive cybersecurity disclosure content. It simply directs the reader to other sections of the filing.


reasoning: The paragraph primarily describes the company's own internal cybersecurity processes (risk assessment, incident detection, vulnerability management, encryption, access controls, training, etc.). Third-party vendor oversight is mentioned as a secondary component of the broader program, not the central topic, so per Rule 3 this remains Risk Management Process. No named frameworks, roles, tools, dates, firms, or any other specific facts appear — every element is generic and could apply to any company unchanged.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity processes (risk assessment, incident detection, vulnerability management, etc.) and also discusses third-party service provider oversight. The majority of the paragraph is about internal processes, with third-party mentioned as a component.

Category: Risk Management Process - the paragraph primarily describes the company's own internal processes. Third-party is mentioned but as one component of the broader program. Per Rule 3, internal processes mentioning vendors as one component → Risk Management Process.

Specificity: Let me check for specific facts:
- No named frameworks, no named roles, no named tools, no dates, no numbers, no named firms

- Everything is generic: "risk assessment," "incident detection," "vulnerability management," etc.
- "depending on the environment" - vague
- No named standards

This is Generic Boilerplate (1).


content_category: Third-Party Risk

reasoning: The entire paragraph centers on third-party cybersecurity partners — their role in the company's strategy, how the company engages them, and the services they provide. While these partners effectively deliver the company's cybersecurity program, the primary communicative purpose is to describe the third-party engagement model itself. No named firms, tools, frameworks, dates, or specific numbers appear; 'industry recognized cybersecurity providers' is unnamed, and the long list of services (vulnerability scanning, IPS/IDS, etc.) are common practices that do not qualify as specific facts.

thinking:
Let me analyze this paragraph from Protara Therapeutics' 10-K filing.

Content: Describes reliance on third-party cybersecurity partners and the services they provide. The central topic is vendor/partner engagement for cybersecurity services.

Category: This is about third-party service providers being central to the company's cybersecurity strategy. The central topic is the role of external partners. However, let me consider - is this about requirements imposed ON vendors (Third-Party Risk) or about the company's own processes that happen to use vendors?

Actually, re-reading: this describes how the company uses third-party partners as part of its cybersecurity infrastructure.

The partners provide services TO the company, but the entire paragraph focuses on these third-party partners themselves rather than internal processes or oversight requirements imposed on them. So this is really about the company's reliance on external cybersecurity providers as a central element of their strategy. The core issue is whether these third-party partners are the company's cybersecurity program itself, or whether they're external entities being managed. Since the partners are actually delivering the security services—monitoring, scanning, incident response—they're functioning as the company's outsourced infrastructure rather than being overseen as vendors. This points toward Risk Management Process, even though third parties are central to the description.

But I keep coming back to the fact that the entire paragraph is really about the partnership arrangement and what these external parties do. The focus isn't on how the company manages its own security; it's on how it engages with and relies on these partners. That makes Third-Party Risk the better fit.

Looking at the specificity: there are no named vendors, no specific frameworks mentioned, no dates or numbers, just generic descriptions of services like vulnerability scanning. The language is vague about which partners and what exactly they provide.


reasoning: The Audit Committee is the grammatical subject performing oversight actions (reviewing IT systems, evaluating the security program), making this Board Governance. No firm-specific facts are present — 'Audit Committee' and 'management' are both on the NOT list as generic governance terms, and the described activities (reviewing IT systems, evaluating security program adequacy) are generic.

thinking:
Classify this paragraph.

The Audit Committee (board committee) reviews with management the IT systems and evaluates security program adequacy. The grammatical subject is the Audit Committee → Board Governance.

Specificity: "Audit Committee" is on the NOT list (generic). "management" is generic. No named frameworks, no firm-specific facts. → Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes — risk assessment, security controls, and incident response planning — making it Risk Management Process. No named frameworks, roles, tools, dates, or other specific facts are present; 'a security team' and 'incident response plan' are generic. The text also appears partially garbled from extraction, but the substantive content is entirely generic process description.

thinking:
Let me analyze this paragraph from DUKE Robotics Corp.'s 10-K filing, Item 1C.

The paragraph describes internal cybersecurity processes: risk assessment, security controls, and incident response planning. It's about the company's own internal processes.

No named roles (just "a security team"), no frameworks, no dates, no specific facts. This is generic boilerplate describing basic program components.

Note: This text appears somewhat garbled/truncated ("cybersecurity a cybersecurity incident response plan") - likely a parsing artifact.

Category: Risk Management Process - describes internal processes
Specificity: Generic Boilerplate - no named standards, no firm-specific facts


reasoning: The entire paragraph is about managing risks associated with vendors and third-party service providers — oversight of external parties is the central topic, not a component of an internal process description. No named frameworks, cybersecurity-specific roles, named firms/tools, dates, or quantified facts appear; 'third-party risk ratings' and 'data classification mapping' are common practices, not firm-specific identifiers.

thinking:
Third-party risk management is the central topic here.

Specific facts: Let me check the IS/NOT lists.
- "third-party risk management processes" - generic program name
- "third-party risk ratings" - this is a specific named process element
- "data classification mapping" - specific process element

Actually, looking more carefully: "third-party risk ratings and data classification mapping" - these are general practices, not firm-specific named programs with unique identifiers.

No named standards, no named roles, no dates, no numbers, no named firms/tools.

This is about vendor oversight as the central topic → Third-Party Risk.

These are standard practices without any firm-specific details or named frameworks, so this falls under generic boilerplate.


reasoning: The paragraph describes which organizational teams oversee the company's cybersecurity risk management processes. Applying the person-vs-function test, no individual person, credentials, or background are described — the content is about the functional structure of the program. The specific five-department composition (Information Technology, Information Security, Product Security, Compliance, Legal) is a firm-specific team composition detail per the IS list.

thinking:
Classify this paragraph.

The paragraph describes who oversees the cybersecurity risk management processes - listing specific team compositions. Let me apply the person-vs-function test: this is about the function/process oversight structure, not about any individual person's credentials or background.

Content category: The paragraph says processes are "overseen by leaders from" specific teams. This is about the management structure overseeing cybersecurity. It's not about the board, not about a specific person's credentials, not about third parties, not about incidents, not about strategy/materiality.

This could be Management Role (reporting/oversight structure) or Risk Management Process.

The grammatical subject is "processes" not a person, so this is really about the organizational structure of the risk management program. The team composition "Information Technology, Information Security, Product Security, Compliance, and Legal teams" is specific departmental composition that matches the firm-specific criteria. So this is Risk Management Process, Firm-Specific (3).

fact: Overseen by leaders from Information Technology, Information Security, Product Security, Compliance, and Legal teams


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes — risk assessments, monitoring, threat landscape analysis, third-party input gathering, vendor oversight, and escalation procedures. Third-party/vendor oversight is one component of the broader internal program, not the central topic. The named board member (Mr. Blattner) appears only in the escalation context at the end. The specific departmental composition ('risk management, legal, information technology, and compliance') and the named individual (Mr. Blattner as designated board member) are firm-specific facts, but no QV-eligible hard facts (dates, dollar amounts, named firms/tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph from Dominari Holdings Inc.'s 10-K filing, Item 1C.

Content: Describes comprehensive cybersecurity risk management process - risk assessments, security measures, monitoring, threat landscape monitoring, third-party input, vendor risk oversight, escalation procedures, and reporting to a named board member.

Category: This is primarily about the company's internal cybersecurity processes. It covers risk assessments, monitoring, third-party engagement as part of the program, vendor oversight, and escalation procedures. The mention of "Mr. Blattner, our designated member of our Board of Directors" is at the very end as part of escalation.

Now I'm checking what's actually firm-specific here. Mr. Blattner is a named individual on the board, and the departmental composition—risk management, legal, information technology, and compliance personnel—are specific to this company. There are no named frameworks like NIST or ISO, and no specific dates, dollar amounts, headcounts, or named third-party vendors mentioned. The specific departmental composition—risk management, legal, information technology, and compliance personnel—qualifies as a firm-specific fact. Combined with Mr. Blattner being named as a designated Board member overseeing cybersecurity, this content is clearly firm-specific with at least one IS fact present.

fact: risk management, legal, information technology, and compliance personnel identify and oversee vendor risks

fact: Mr. Blattner, designated board member for cybersecurity escalation


reasoning: The Board and Audit Committee are the grammatical subjects performing oversight and receiving reports, making this Board Governance. All elements—Board, Audit Committee, CFO, quarterly cadence—appear on the IS-NOT list; CFO is generic C-suite, not a cybersecurity-specific title, so no firm-specific facts remain after validation.

thinking:
Let me analyze this paragraph.

Content: Board oversight, delegation to Audit Committee, CFO reports quarterly to Audit Committee on cybersecurity.

Category: Board Governance - the Board/Audit Committee is the primary subject, describing oversight structure and briefing cadence.

Specificity: Let me check facts:
- "Board" - generic (NOT list)
- "Audit Committee" - generic (NOT list)
- "CFO" - generic C-suite (NOT list)
- "quarterly" - generic cadence (NOT list)

No named frameworks, no cybersecurity-specific titles (CFO is generic C-suite), no specific dates, no named tools/firms.

This is generic boilerplate.


reasoning: The paragraph describes a specific business email compromise incident: a threat actor impersonated a CFO and redirected a BTC transfer. It includes specific date (2023), named third parties (Sphere 3D Corp., Gryphon), a quantified amount (26 BTC, ~$560,000), and law enforcement engagement — well exceeding the two-fact QV threshold.

thinking:
Incident disclosure - describes a specific cybersecurity incident with details.

Specific facts: "2023" (date), "Sphere 3D Corp." (named firm), "26 BTC" (quantified), "$560,000" (dollar amount), "Gryphon" (named firm). Multiple QV facts.

fact: Sphere 3D Corp.

fact: 26 BTC transferred

fact: approximately $560,000

fact: Gryphon (engaged via counsel)


specificity_confidence: medium

reasoning: The paragraph describes the company's own internal cybersecurity processes — firewall solutions, antivirus/patch management, an internal cloud system, and magnetic tape backup procedures. This is squarely about the company's internal risk management activities. Despite being descriptive of particular technical choices (Layer 7 firewalls, magnetic tapes, internal cloud), none of these are named products/tools (Layer 7 is an OSI model category, not a brand), no recognized frameworks are cited, no cybersecurity-specific roles are named, and no specific dates, headcounts, or dollar amounts appear. After filtering against the IS/NOT lists, no qualifying specific facts remain.

thinking:
Let me analyze this paragraph.

Content: Describes the company's internal cybersecurity processes - firewall solutions, antivirus systems, internal cloud, backup procedures. This is about the company's own internal processes and tools.

Category: Risk Management Process - describes internal cybersecurity processes, tools, and methodologies.

Specificity analysis:
- "Layer 7 firewall solutions" - this is a specific technology type/category, not a named product. It's a technical term but not a brand name.

- The antivirus system, internal cloud architecture, magnetic tape backups, and fireproof storage are all generic descriptions without named products or specific identifiers.

Checking against the IS list, there are no named frameworks, cybersecurity titles, committees, dates, products, firms, or specific numbers mentioned - just general technical categories and processes. Layer 7 firewalls are just a technology category, not a named product, so they don't fit the IS list criteria. The internal cloud system and magnetic tape backups are company-specific implementations, but without unique names or references to standards, they fall into generic boilerplate territory. I'm settling on Risk Management Process with Generic Boilerplate classification.


reasoning: The paragraph contains an explicit materiality assessment ('has not experienced any material cybersecurity events' and 'could have a material and adverse impact on the business, results of operations, and financial position'), which per Rule 6 makes this Strategy Integration regardless of the appended cross-reference to Risk Factors. No named frameworks, roles, dates, or firm-specific facts — purely boilerplate materiality language.

thinking:
Let me analyze this paragraph.

Content: Materiality assessment ("has not experienced any material cybersecurity events") + forward-looking risk language + cross-reference to Risk Factors.

Category: The paragraph makes a materiality assessment ("has not experienced any material cybersecurity events" and "could have a material and adverse impact on the business, results of operations, and financial position"). Per Rule 6, materiality disclaimers → Strategy Integration. The cross-reference doesn't change this.

Specificity: No named frameworks, no specific facts from the IS list. Boilerplate materiality language. → Generic Boilerplate.


reasoning: The paragraph describes planned internal cybersecurity processes (risk assessments targeting systems, data, and infrastructure), making it Risk Management Process. The use of future tense ('will include') and entirely generic language with no named frameworks, roles, or firm-specific details places this at Generic Boilerplate.


reasoning: The paragraph describes integrating cybersecurity into the broader ERM framework to evaluate cyber risks alongside other risk types — this is a description of the company's own internal risk management methodology. It contains no named frameworks, no firm-specific facts, no named roles, dates, or tools; the language is entirely generic and could apply to any company.

thinking:
Classify this paragraph.

This describes embedding cybersecurity within ERM - it's about internal processes/methodology.

Content: Risk Management Process - ERM integration, evaluating cyber risks alongside other risks.

Specificity: No named frameworks, no firm-specific facts, no dates, no names. Generic language. → Generic Boilerplate.


reasoning: The board of directors is the grammatical subject overseeing cybersecurity risks, making this Board Governance. The paragraph contains no named frameworks, cybersecurity-specific roles, dates, or any facts from the IS list — 'board of directors' is generic governance, and the remaining language ('formalizing governance structures,' 'operational integrity,' 'stockholder confidence') is boilerplate that could appear in any filing.

thinking:
Classify this paragraph.

The board is the primary subject in the first sentence. Second sentence talks about formalizing governance structures. This is about board oversight of cybersecurity risks.

But wait - "We are in the process of formalizing governance structures" - this is quite generic and almost suggests they don't have formal structures yet. Similar to a SPAC-like situation but not explicitly stating no operations.

Category: Board Governance - the board is the grammatical subject, and the paragraph is about oversight of cyber risk.

Specificity: No named frameworks, no specific facts from the IS list. "Board of directors" is on the NOT list.

The lack of a CISO, named committees, dates, or concrete details points to this being generic boilerplate.


content_category: Management Role

reasoning: The grammatical subject is 'our management,' describing their responsibility for cybersecurity oversight and board notification procedures — making it Management Role rather than Board Governance. However, the content is entirely generic: no cybersecurity-specific titles (CISO, CIO, etc.), no named individuals, no credentials, no reporting structure. 'Management' is on the NOT list. The trailing 'Public Offering' fragment appears to be an extraction artifact and contains no disclosure content.

thinking:
Let me analyze this paragraph from Solidion Technology Inc.'s 10-K filing, Item 1C.

The paragraph says management oversees cybersecurity threats and would notify the board in case of incidents. The "Public Offering" at the end seems like an erroneous extraction artifact.

Category: This is about management's role in overseeing cybersecurity. But let me apply the person-vs-function test. There's no specific person named, no credentials, no background. It's about what "management" does generically. However, the grammatical subject is "our management" and it describes their responsibility.

Actually, this is quite generic - "management oversees assessment and management of cybersecurity threats" and "shall promptly notify our board." There's no named role (CISO, CIO, etc.), just generic "management." The "Public Offering" fragment at the end suggests erroneous extraction.

The grammatical subject is clearly "our management" describing their oversight and notification responsibilities, so I'm leaning toward Management Role. But this is extremely thin and generic—no named positions, no specific individuals, just a boilerplate description of what management does. The "Public Offering" noise at the end reinforces that this might be from a company with minimal operations, though the text doesn't explicitly state that. I'll classify it as Management Role since that's what the paragraph is structurally about, even though it lacks any real substance or specificity. I'm working through whether this disclosure fits the Management Role category—the text does address management's cybersecurity oversight responsibilities, even if it's generic and lacks specifics. The key issue is that "management" appears on the exclusion list for titles, but here it's functioning as the grammatical subject performing the oversight action, which makes Management Role the appropriate fit. So I'm settling on Management Role for the category and Generic Boilerplate for specificity since there are no concrete facts or named frameworks present.


reasoning: The paragraph describes the company's own internal cybersecurity processes (authentication, training, logging, encryption, vulnerability scanning, phishing simulations) and mentions external service providers as one component — making it Risk Management Process. No named frameworks, no cybersecurity-specific roles, no dates, no named tools or firms; all items listed are common practices on the NOT list, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes internal cybersecurity processes - authentication, training, logging, encryption, vulnerability scanning, phishing simulations, and use of external service providers.

Category: Risk Management Process - describes the company's own internal processes. The external service providers are mentioned as one component, not the central topic.

Specificity: Let me check for specific facts.
- "IT Security Policy" - generic program name, no unique identifier
- Authentication, training, logging, encryption, vulnerability scanning, phishing simulations - all common practices (on the NOT list)
- "external service providers" - unnamed entities (NOT list)
- No named frameworks, no named roles, no dates, no numbers, no named tools

- This falls into generic boilerplate with no identifiable information security facts or named standards.


reasoning: This is a SPAC with no business operations that explicitly states it has no cybersecurity risk management program or formal processes. The board mention is perfunctory ('generally responsible... if there is any'), and the absence of a program is not a description of a program. Per the codebook's SPAC/no-operations rule, this is None/Other.

thinking: SPAC, no operations, no program.


reasoning: Arogo Capital is a SPAC ('Acquisition Corp.'). This paragraph is generic risk language stating cybersecurity threats 'could have a material adverse effect' — a hypothetical warning, not a materiality assessment conclusion, nor a description of any program, process, or governance structure. It contains no substantive cybersecurity disclosure content; every sentence is boilerplate that could appear in any filing unchanged.

thinking:
Let me analyze this paragraph from Arogo Capital Acquisition Corp., which appears to be a SPAC based on the name "Acquisition Corp."

The paragraph is generic risk language about cybersecurity threats. It doesn't describe any program, process, board oversight, management role, or actual incident. It's essentially boilerplate risk acknowledgment.

The company name suggests it's a SPAC. The language is very generic - "we believe cybersecurity is critical," "face a multitude of cybersecurity threats," "material adverse effect" - all boilerplate.

No specific facts, no frameworks, no named roles, no dates, no specifics whatsoever.

This is just hypothetical risk language without any materiality assessment or conclusion. It doesn't actually state whether threats have or haven't materially affected the company - it's purely speculative boilerplate. I'd classify this as None/Other with a specificity score of 1.


reasoning: The CFO is the primary actor ('under the ultimate direction of our CFO') directing cybersecurity governance, with the Board mentioned in a subordinate oversight role. However, the paragraph describes no credentials, background, or qualifications — it merely establishes organizational responsibility. CFO is a generic C-suite title (NOT list), 'the Board' is generic governance, and 'security governance structure' names no framework or firm-specific detail, yielding Generic Boilerplate.

thinking:
Classify this paragraph.

Content: "Under the ultimate direction of our CFO, with oversight from the Board, we maintain a security governance structure to evaluate and address cyber risk."

Category: This mentions CFO directing, Board oversight, and a security governance structure. The primary action is maintaining a governance structure. CFO is the grammatical subject directing it. But CFO is a generic C-suite title (on the NOT list). The paragraph describes a governance structure to evaluate and address cyber risk.

This is a blend of management and board governance. The CFO is the primary actor ("under the ultimate direction of our CFO"), with the Board mentioned as oversight. Per the person-vs-function test, this is about the structure/function, not about the person's credentials.

The core focus here is the organizational structure itself—who's responsible for what. The CFO directs the cybersecurity governance while the Board provides oversight, but since the CFO is a generic C-suite role and the paragraph emphasizes the governance structure and its function rather than the individual's qualifications, this is fundamentally about the organizational framework. I'm checking whether this paragraph actually contains any specific details about cybersecurity practices, frameworks, or measurable facts—it doesn't, just generic governance language about reporting lines and oversight responsibility.


reasoning: The paragraph describes an actual cybersecurity incident — an email spoofing attempt in May 2014 — including the nature of the attack, how it was detected, and the outcome (no money lost). The specific date (May 2014) is the sole hard verifiable fact, placing this at Firm-Specific rather than Quantified-Verifiable.

thinking:
Classify this paragraph.

This describes an actual cybersecurity incident - email spoofing in May 2014. It describes what happened, when, the nature of the attack, and the outcome.

Content category: Incident Disclosure

Specific facts:
- "May 2014" - specific date
- That's about it for hard verifiable facts.

Only one hard verifiable fact (May 2014), so not QV. But it is a specific date → Firm-Specific.

Specificity: Firm-Specific


reasoning: The paragraph focuses on management's preparedness to assess cybersecurity risks — the CFO and other members of management underwent briefings to build their competence. This is about the people and their readiness (Management Role), not about processes or tools. However, CFO is generic C-suite per the NOT list, the advisory firm is unnamed, and the third-party providers are unnamed, so no specific facts survive validation — Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Talks about CFO and management getting briefings from cybersecurity advisory firm, and third-party providers having experience/certifications.

Category: This is about management preparedness - but the CFO is not a cybersecurity-specific role. The paragraph describes training/briefings management received and third-party provider qualifications.

The person-vs-function test: Is this about the person or the function? It's about management being briefed/prepared - not about their credentials per se, but about a process of preparing them. The CFO is generic C-suite. But the paragraph is about management's preparation to assess cyber risks, which is more about the management role's readiness.

I'm noticing the CFO falls under the generic C-suite exclusion, and "members of management" is also generic. The advisory firm and service providers are unnamed too. So the real substance here is about the management function itself - specifically, how prepared they are to oversee cyber risk. That's the Management Role category, since it's describing the readiness and responsibility of those in management positions rather than specific individuals or their personal qualifications.


reasoning: The paragraph describes incident response actions (forensic analysis, control modifications, restitution payment) and forensic findings about a cybersecurity incident involving stolen BTC. While it includes financial impact ($560,000), the dominant content is the incident narrative — what happened, what the forensic analysis revealed, and what remediation was taken — making it Incident Disclosure rather than Strategy Integration. Three hard verifiable facts (specific quarter, dollar amount, named firm Sphere 3D) qualify it as Quantified-Verifiable.

thinking:
Let me analyze this paragraph from American Bitcoin Corp.'s 10-K filing, Item 1C.

Content: Describes aftermath of a cybersecurity incident - payment to make whole for stolen BTC, forensic analysis, findings, control modifications, and specific financial impact ($560,000 payment in Q2 2023).

Category: This describes what happened in response to an incident - forensic analysis, findings, remediation, and financial impact. The paragraph describes incident response actions (forensic analysis, control modifications) AND financial impact ($560,000). The dominant content is about what happened - the response actions and findings. The financial detail is one element. I'd say this is Incident Disclosure since it describes response actions, forensic findings, and remediation, with the dollar amount being part of the incident narrative.

The tiebreaker confirms this - the paragraph includes substantial response actions and forensic findings about how the threat actor gained entry, not just the financial cost in isolation. That makes it Incident Disclosure. I'm also noting the specificity here: the exact quarter (June 30, 2023), the precise dollar amount ($560,000), and the named third-party firm conducting the forensic work (Sphere 3D).

fact: Sphere 3D (named counterparty)


reasoning: The paragraph describes the company's incident response plan activities — preparation, detection, response, recovery, triage, escalation, containment, investigation, and remediation. This is squarely about internal cybersecurity processes. No named frameworks, no firm-specific facts; 'incident response plan' is a generic program name per the NOT list.


reasoning: The paragraph describes an actual email spoofing incident with detailed timeline, scope, response actions, and remediation measures — squarely Incident Disclosure. Multiple hard verifiable facts (four specific dates plus a dollar amount) easily meet the two-fact QV threshold.

thinking:
Classify this paragraph.

Content: Describes an actual email spoofing incident - dates, amounts, what happened, response actions, remediation measures.

Category: Incident Disclosure - this is clearly describing what happened in a cybersecurity incident.

Specificity: Let me count QV-eligible hard facts:
1. Specific date: April 9, 2024
2. Specific date: April 11, 2024
3. Specific date: March 27, 2024

4. Dollar amount: $30,825
5. Specific date: April 12, 2024
6. Named role: CISO (firm-specific but not QV)

With multiple concrete dates and a specific dollar amount, this clearly qualifies as Quantified-Verifiable.

fact: April 9, 2024 (incident detection date)

fact: April 11, 2024 (verification date)

fact: March 27, 2024 (wire transfer date)

fact: $30,825 wire transfer amount

fact: April 12, 2024 (remediation actions adopted)

fact: Chief Information Security Officer


reasoning: The paragraph primarily describes the company's internal cybersecurity processes — incident response plan, governance structure, regulatory compliance, and framework development — making Risk Management Process the dominant category. Third-party/supply chain risk and a brief materiality mention are subordinate components. The mention of FDA (Federal Drug Administration) as a specific regulator with patient-information safeguarding requirements functions as a named regulatory standard, triggering Sector-Adapted. However, no firm-specific facts from the IS list are present: external firms are unnamed, frameworks are unnamed ('pre-existing third party frameworks,' 'our own practices'), and no specific roles, dates, tools, or numbers appear.

thinking:
Let me analyze this paragraph from Aditxt, Inc.'s 10-K filing, Item 1C.

This paragraph covers multiple topics: incident response plan, external firms, governance structure, regulatory compliance (FDA), SEC compliance, frameworks, supply chain risk, and subcontractor requirements.

The dominant theme is the company's risk management processes - it describes their incident response plan, governance structure, compliance efforts, and frameworks. There are also elements of third-party risk (supply chain, subcontractors) and strategy integration (materiality mention about supply chain).

Applying Rule 1 (dominant category): The paragraph primarily describes the company's internal cybersecurity processes - incident response plan, governance structure, compliance, frameworks.

Third-party risk appears as a supporting element rather than the main focus. The materiality reference is minimal. Looking at the specificity, I see generic program names like "cybersecurity incident response plan" and unnamed references to "external firms" and "third party frameworks." The FDA is mentioned as a regulator rather than a recognized standard like NIST or ISO, and there are no named frameworks, specific dates, identified firms, defined roles, or numerical metrics present.

The FDA reference is interesting—it's a named regulatory body, but the codebook distinguishes between naming a specific regulation like HIPAA or GDPR versus just referencing a regulator. FDA safeguarding requirements for patient information do constitute a specific regulatory requirement, which could push this toward Sector-Adapted. But looking at the actual definition for that classification, it requires naming a specific recognized framework or standard, and FDA as a regulator doesn't quite fit that criterion the way NIST or ISO would. This still reads as Risk Management Process with limited specificity. FDA is a named specific regulator, so this qualifies as Sector-Adapted. My classification is Risk Management Process with Sector-Adapted specificity level 2.


reasoning: The entire paragraph describes three individuals' qualifications, credentials, career backgrounds, and experience — squarely about the persons, not the functions they perform. Multiple QV-eligible hard facts: specific years of experience (24, 28, 20), named certifications (CISA, CRISC, FINRA Series 99), and named degrees (PhD in computer science) easily exceed the two-fact threshold.

thinking:
This paragraph describes three specific individuals' qualifications, credentials, and backgrounds.

Content category: Management Role - entirely about the persons (credentials, experience, career history)

Specific facts:
- CISO (cybersecurity-specific role)
- Bachelor of Arts in computer science
- 24 years experience
- CISA certification
- CRISC certification
- FINRA Series 99
- CTO (cybersecurity-specific role)
- PhD in computer science
- MBA
- 28 years experience
- Head of IT Infrastructure
- 20 years experience

QV-eligible: 24 years, CISA, CRISC, Series 99, PhD, 28 years, 20 years - easily 2+ hard verifiable facts.

Quantified-Verifiable.

fact: CISO role

fact: over 24 years in information technology

fact: CISA certification

fact: CRISC certification

fact: FINRA Series 99 registration

fact: CTO role

fact: PhD in computer science

fact: over 28 years in information technology

fact: Head of IT Infrastructure role

fact: over 20 years in information technology


reasoning: This paragraph is a cross-reference directing the reader to Item 1A Risk Factors for cybersecurity risk information. While it uses the phrase 'materially affect,' it does not make a materiality conclusion — it merely describes what the reader will find elsewhere ('see our risk factors'). Per the codebook, a pure cross-reference with no standalone materiality assessment is None/Other. The quoted risk factor caption is metadata, not disclosure content.

thinking:
This is a cross-reference paragraph that points to Risk Factors. It mentions "materially affect" but in the context of directing the reader elsewhere ("see our risk factors"), not making a materiality conclusion itself. Let me check the rules.

The paragraph says "risks from cybersecurity threats that may materially affect the Company and how they may do so, see our risk factors..." - this is directing the reader to another section for the materiality discussion. It's not making a materiality assessment itself (like "have not materially affected"). It's a pure cross-reference.

Per the codebook: "A pure cross-reference ('See Item 1A, Risk Factors') with no materiality assessment is None/Other."

Since this is just descriptive language pointing elsewhere without actually concluding whether cybersecurity has materially affected the company, it still qualifies as a pure cross-reference with no materiality assessment.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes — vulnerability assessments, penetration testing, enterprise risk assessments, ERM integration, and rebuild/recovery protocols. The CISO is mentioned twice: once as attribution for overseeing the risk assessment and once in a closing sentence about qualifications. Applying the person-vs-function test, if you remove the CISO references the paragraph still reads as a coherent process description, so the dominant content is the function, not the person. For specificity, CISO is a cybersecurity-specific title (IS list → Firm-Specific), and 'over 20 years of experience' is a QV-eligible fact, but named roles do not count toward QV, leaving only one QV-eligible hard fact — insufficient for Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. Vulnerability assessments and penetration testing
2. Enterprise information risk assessment
3. CISO oversight of the risk assessment
4. Risk assessment details (internal/external threats, rebuild/recovery protocols)
5. ERM integration
6. CISO qualifications (over 20 years of experience)

Person-vs-function test: The bulk of the paragraph is about processes - vulnerability assessments, pen tests, risk assessments, ERM integration. The CISO is mentioned twice: once as overseeing the risk assessment, and once at the end with "over 20 years of experience." The last sentence is about the person's qualifications, but the dominant content is about processes.

This is categorized as a Risk Management Process since the focus is on what the program does—assessments, penetration testing, and ERM integration—with the CISO attribution and a single qualification statement at the end. The "over 20 years of experience" is a specific number that qualifies as a QV-eligible fact, while the CISO title itself is firm-specific but not QV-eligible.

fact: Chief Information Security Officer (CISO)

fact: over 20 years of experience managing IT and cybersecurity


reasoning: The paragraph describes the company's internal cybersecurity controls (firewalls, endpoint detection, vulnerability management, backups) and third-party risk processes (pre-acquisition diligence, contractual obligations). The CISO and CIO are mentioned as attribution for oversight but the substantive content is about what the program does — applying the person-vs-function test, removing the role titles leaves a complete process description. Third-party risk is one component, not the central topic. CISO and CIO are cybersecurity-specific titles on the IS list, making this Firm-Specific, but no QV-eligible hard facts (dates, amounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

Content: Describes the cybersecurity organization, its place in the org structure (under CISO, within IT under CIO), lists security controls, and mentions third-party risk processes.

Category: The paragraph describes what the cybersecurity organization does - security controls, processes. The CISO and CIO are mentioned as attribution for who oversees what. Applying the person-vs-function test: if I remove "overseen by our CISO" and "overseen by our CIO", the paragraph still describes the security controls and processes. This is Risk Management Process. Third-party risk is mentioned but as one component of the broader program.

The IS facts here are the CISO and CIO titles, which are cybersecurity-specific, but there aren't any quantifiable details like dates, amounts, headcounts, or named products to make this QV-eligible. The controls and processes mentioned are too generic. This lands in Firm-Specific since it has IS facts but lacks the two QV-eligible facts needed for a higher classification.

fact: Chief Information Officer (CIO)


reasoning: The paragraph describes two activities: an enterprise risk management assessment (overseen by the CISO, addressing email spoofing safeguards) and established Audit Committee briefings. The first item contains more substantive detail about internal processes (determining safeguards, technology-based and process-based), making Risk Management Process the dominant category over Board Governance. The CISO title is the sole IS-list fact, yielding Firm-Specific.

thinking:
Let me analyze this paragraph.

Content: Describes two items - an enterprise risk management assessment overseen by the CISO, and established regular cybersecurity briefings to the Audit Committee.

Category: The paragraph has two components - a risk management assessment (overseen by CISO) and Audit Committee briefings. The first part is about an internal process (risk assessment for email spoofing), the second is about board governance (Audit Committee briefings). The dominant content seems to be about the risk management process - the assessment to determine safeguards. The Audit Committee briefing is a secondary element.

Looking at these as bullet points, the first one describing the risk assessment process is more detailed and substantive than the second one about Audit Committee briefings, so the dominant category here is Risk Management Process.

Specificity: CISO is mentioned, which indicates this falls under the IS list.

"Audit Committee" is generic, not firm-specific. "Email spoofing" is a common threat type, not a firm-specific fact. There are no named frameworks, dates, dollar amounts, or other firms mentioned.

With only one IS fact (CISO as a named role), this qualifies as Firm-Specific at level 3. The CISO reference isn't QV-eligible since it's just a role name, not a quantifiable metric.


reasoning: The paragraph's central topic is the company's reliance on third-party SaaS providers and the attestation standards (SSAE audits) those providers must meet, making vendor oversight the primary subject. SSAE is a named attestation standard triggering Sector-Adapted, but there are no firm-specific facts (no named vendors, no headcounts, no specific dates) to reach Firm-Specific.

thinking:
Classify this paragraph.

The paragraph discusses third-party SaaS providers and their SSAE audits. The central topic is about requirements/standards imposed on/expected from third-party providers.

Content category: Third-Party Risk - the central topic is oversight of external parties (SaaS providers) and their compliance (SSAE audits).

Specificity: "SSAE" is a named standard (Statement on Standards for Attestation Engagements). This is essentially the SOC 2 family of standards. So Sector-Adapted at minimum. But is there anything firm-specific? "cloud-first strategy" is a company-specific strategic choice, but it's not on the IS list.

There's nothing here that points to firm-specific details—no particular roles, committees, dates, firms, or metrics mentioned. While "cloud-first strategy" and "SaaS-based solutions" reflect a company approach, they don't meet the IS criteria. The named standard SSAE pushes this to Sector-Adapted.

Specificity: Sector-Adapted (2).

fact: SSAE audits (Statement on Standards for Attestation Engagements)

type: framework


reasoning: The paragraph contains an explicit materiality assessment ('not aware of any material risks from cybersecurity threats... that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition'), which per Rule 6 is Strategy Integration even though boilerplate. The appended cross-reference to Risk Factors and the lengthy risk factor title do not change the classification. No firm-specific facts, named frameworks, or verifiable details are present.

thinking:
Classify this paragraph.

Content: Materiality assessment ("not aware of any material risks... that have materially affected or are reasonably likely to materially affect us, including our business strategy, results of operations, or financial condition") + forward-looking caveat + cross-reference to Risk Factors.

Per Rule 6 and the codebook: materiality disclaimer → Strategy Integration. The cross-reference doesn't change it.

Specificity: The materiality language is boilerplate. No specific facts from the IS list. → Generic Boilerplate.


reasoning: The paragraph describes the company's Incident Response Plan (IRP) design, its controls and procedures, escalation process, and NIST CSF alignment — all internal process descriptions. The Audit Committee mention is subordinate (an escalation step within the process, not board oversight as the primary topic). NIST CSF is a named standard pushing to Sector-Adapted, but 'IRP' is just a generic abbreviation for incident response plan (no unique identifier), and Audit Committee is on the NOT list, so no firm-specific facts exist.

thinking:
Let me analyze this paragraph.

Content: Describes the IRP (Incident Response Plan) purpose, controls, escalation to Audit Committee, and NIST CSF alignment. This is primarily about internal processes - the IRP design, its controls, and framework alignment. The Audit Committee mention is subordinate (escalation path as part of the process). Primary topic is Risk Management Process.

Specific facts:
- "IRP" - generic abbreviation for incident response plan, not a unique identifier
- "Audit Committee" - on the NOT list

- "NIST Cybersecurity Framework" - named standard → Sector-Adapted

No firm-specific facts from the IS list. The IRP is just "incident response plan" abbreviated - not a unique named program. No cybersecurity-specific roles, no dates, no numbers, no named firms/tools. The only specificity here is the reference to NIST CSF, which qualifies as a sector-adapted standard at Level 2 classification.

fact: NIST Cybersecurity Framework


reasoning: The paragraph briefly names a VP of IT services and a reporting line to the Chief Strategy Officer, but the dominant content describes what the IT security team does: overseeing the cybersecurity program, measuring/managing risk, prevention/detection/mitigation/remediation, implementing policies, and incident reporting to stakeholders. Applying the person-vs-function test, removing the VP title and reporting line leaves a fully coherent process description. The VP of IT services title qualifies as a cybersecurity-specific role (IS list), yielding Firm-Specific, but there is only one QV-eligible fact so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes the IT Department's role in cybersecurity, led by VP of IT services who reports to Chief Strategy Officer. Describes the security team's responsibilities - overseeing cybersecurity program, managing risk, prevention/detection/mitigation/remediation, implementing policies. Reports incidents to senior management.

Category: This is about the function/program - what the IT department and security team DO. The VP of IT services is mentioned with a reporting line, but the bulk is about processes and responsibilities. Apply person-vs-function test: remove the VP title and reporting line, the paragraph still describes what the security team does. → Risk Management Process.

Though there's a reporting structure mentioned with the VP and Chief Strategy Officer, the real substance here is what the security team actually does—the processes and responsibilities they own. The organizational hierarchy is secondary to describing their functions.

Looking more closely at the titles: "vice president of information technology services" maps closely to "VP of IT" on the specificity list, so that counts as a firm-specific fact. "Chief Strategy Officer" is generic C-suite language that doesn't qualify. The cross-functional group reference is too vague. So I'm seeing one IS-eligible fact here with no quantifiable data like dates, budgets, or headcounts—this lands at Firm-Specific level 3.

fact: Vice President of Information Technology Services leads the function


reasoning: The paragraph primarily describes remediation actions completed after a cybersecurity incident (forensic investigation, automated off-boarding, SIEM/SOC monitoring, training, domain stabilization), making Incident Disclosure the dominant category. The closing materiality sentence is subordinate to the incident response narrative. No named tools, firms, dates, frameworks, or cybersecurity-specific roles appear — SIEM/SOC are generic acronyms, 'forensic investigation' is standard incident language, and 'quarterly' is a generic cadence — so specificity remains Generic Boilerplate.

thinking:
Let me analyze this paragraph carefully.

Content: Describes remediation actions after an incident (forensic investigation, automated off-boarding, SIEM/SOC monitoring, training, domain/DNS/email stabilization, quarterly access reviews) and concludes with a materiality assessment.

Category: This is primarily about what happened after an incident - remediation actions taken. The bulk of the paragraph describes response actions (completed forensic investigation, established monitoring, conducted training, stabilized operations). The last sentence is a materiality disclaimer. The dominant content is incident response/remediation actions → Incident Disclosure. The materiality sentence is subordinate.

Checking the specificity here - I'm seeing generic language throughout. The forensic investigation, off-boarding processes, SIEM/SOC monitoring, and quarterly reviews are all standard incident response terminology without any named tools, specific dates, dollar figures, or identified individuals. No frameworks are referenced either. This reads as boilerplate language rather than concrete facts from the incident.


reasoning: The paragraph contains an explicit materiality assessment ('business strategy, results of operations, and financial condition have not been materially affected by cybersecurity incidents'), which per Rule 6 is Strategy Integration even though a cross-reference to Risk Factors is appended. No firm-specific facts, named standards, or verifiable details are present — the materiality language is boilerplate.

thinking:
Classify this paragraph.

This paragraph contains a materiality assessment ("business strategy, results of operations, and financial condition have not been materially affected") plus a cross-reference to Risk Factors. Per Rule 6, materiality disclaimers → Strategy Integration. The cross-reference doesn't change that.

Specificity: No named standards, no firm-specific facts from the IS list. Generic boilerplate materiality language.


reasoning: The paragraph describes the company's internal cybersecurity risk management framework, ERM integration, defense-in-depth approach, and various activities (vulnerability scans, penetration tests, tabletop exercises, training, insurance, incident response). All content is about internal processes and methodology. No named frameworks (NIST, ISO), no cybersecurity-specific titles, no named tools/firms, no specific dates or numbers — all items are common practices and generic program names that could apply to any company.

thinking:
Let me analyze this paragraph.

Content: Describes the bank's cybersecurity risk management framework, defense-in-depth approach, ERM integration, Information Security program activities (control assessments, vulnerability scans, penetration tests, threat intelligence), and mitigation activities (policy, training, tabletop exercises, insurance, incident response plan, business continuity).

Category: This is clearly about the company's internal cybersecurity processes and methodology. → Risk Management Process

Specificity: Let me check for specific facts.

IS list check:
- "defense-in-depth" — common practice concept, not firm-specific

- Enterprise Risk Management program, Information Security program, Information Security Policy, Cybersecurity Incident Response Plan, business continuity management program — all generic program names
- Control assessments, vulnerability scans, penetration tests, threat intelligence feeds, tabletop exercises, training — standard industry practices
- Cybersecurity insurance mentioned without specifics

No named frameworks, roles, dates, tools, firms, or numbers present.

→ Generic Boilerplate (1)


reasoning: The CISO and Cybersecurity Committee are the grammatical subjects performing oversight actions. The paragraph describes management-level oversight structure (who oversees and who is informed) rather than the processes themselves, which are only cross-referenced ('those described above'). Applying the person-vs-function test, the content is about the management structure, not process details. CISO (cybersecurity-specific title) and Cybersecurity Committee (named non-generic committee) each qualify as IS-list facts for Firm-Specific, but neither counts toward QV.

thinking:
Let me analyze this paragraph.

The paragraph mentions the CISO and Cybersecurity Committee overseeing policies and processes. Let me apply the person-vs-function test.

The paragraph describes what the CISO and Cybersecurity Committee do (oversee policies, monitor prevention/detection/mitigation/remediation). It's about the function/oversight role, not about the person's credentials.

But who is the grammatical subject? "Our CISO and the Cybersecurity Committee" - this is a mix of management and committee. The Cybersecurity Committee is a named non-generic committee (IS list).

The key question is whether this is describing the management structure and oversight responsibilities, or if it's really about a governance process. The paragraph focuses on what they oversee and monitor, which points toward Risk Management Process rather than board-level governance.

Looking at specificity: the CISO is a firm-specific cybersecurity role, and the Cybersecurity Committee is a named committee from their internal structure. Neither of these are generic terms. There are no hard verifiable facts that would trigger the QV check. This lands at Firm-Specific (Level 3).

fact: Chief Information Security Officer

fact: Cybersecurity Committee


reasoning: The paragraph's primary content is about the CIO as a person — their 30+ years of experience, career history in professional services, and when they joined Huron — plus the ISMS Committee structure and composition, which is a management committee responsible for cybersecurity. While the ISMS Committee's activities are described, this serves to explain the management governance structure rather than detailing internal cybersecurity processes. Two QV-eligible hard facts (30 years of experience + 2018 joining date) reach the Quantified-Verifiable threshold.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes:
1. The CIO's experience (30+ years), background (joined Huron in 2018, prior roles in professional services), and reporting line
2. The ISMS Committee - its composition and responsibilities
3. What the ISMS Committee does (reviews, approves, establishes goals, etc.)

Person-vs-function test: The paragraph starts by describing the CIO's qualifications, experience, and career history - that's about the person. Then it transitions to the ISMS Committee's role and activities.

The CIO's credentials and background take up roughly the first half.

The ISMS Committee description takes the second half, and it's about organizational structure - who sits on it and what responsibilities it holds. This falls under Management Role since it covers management committees responsible for cybersecurity and the reporting structure. The paragraph is fundamentally about who leads the program and how the management committee is structured.

Category: Management Role

Specificity: The CIO has a cybersecurity-specific title and over 30 years of experience - that's concrete detail. The ISMS Committee composition and responsibilities are also specific facts about the governance structure.

Now I'm checking what's verifiable. The CIO joined Huron in 2018 - that's a specific date. The "over 30 years" of experience is a quantified number. Those are the two hard facts I can verify: the specific date and the years of experience. That makes this Quantified-Verifiable.

fact: over 30 years of relevant work experience

fact: joined Huron in 2018

fact: Information Security Management System (ISMS) Committee


reasoning: The paragraph briefly mentions a past incident (May 2020 ransomware attack, data exfiltration) but its dominant communicative purpose is the ongoing business/legal/financial consequences — legal proceedings, claims, fines, penalties, and a cross-reference to financial statement notes for impact details. Per the tiebreaker, brief mention of a past incident with business impact as the main point → Strategy Integration. One QV-eligible fact (specific date May 2020) yields Firm-Specific.

thinking:
Let me analyze this paragraph from Blackbaud's 10-K filing.

Content: Describes a past ransomware attack (May 2020), its consequences (legal proceedings, data exfiltration), and references financial statement notes. It's describing an actual incident and its business/legal impact.

Category analysis:
- It references a real incident (May 2020 ransomware attack) with specific details
- But the primary focus is on the ongoing business/legal consequences - legal proceedings, claims, fines, penalties
- There's a cross-reference to Note 11 for financial impact

- The incident itself gets minimal description while the materiality and financial impact dominate the paragraph's purpose

This looks like Strategy Integration rather than pure Incident Disclosure—the brief incident mention serves mainly as context for discussing the ongoing legal and financial consequences.

For QV-eligible facts, I'm only finding one concrete verifiable detail: the specific date of May 2020. The ransomware attack type and self-hosted environment are descriptive but not independently verifiable facts in the QV sense, so that puts this as Firm-Specific with just one hard fact.

fact: May 2020 ransomware attack


reasoning: The paragraph describes the company's general approach to cybersecurity measures (safeguarding information systems, protecting data confidentiality/integrity/availability), which falls under Risk Management Process. However, it is entirely generic boilerplate with no named frameworks, roles, tools, dates, or any company-specific detail — it could be pasted into any company's filing unchanged.

thinking:
Classify this paragraph.

This is a generic statement about recognizing the importance of cybersecurity. No frameworks, no specific facts, no named roles or committees.

Category: Risk Management Process - it's about the company's approach to cybersecurity measures, but it's really just a generic opening statement. Could also be None/Other since it's so generic. But it does reference "developing, implementing, and maintaining robust cybersecurity measures" which is about their internal processes, even if vaguely.

I'll go with Risk Management Process - it's talking about the company's own cybersecurity measures, even though it's extremely generic.

Specificity: Generic Boilerplate - no specific facts at all.


reasoning: The paragraph describes a specific cybersecurity incident: unauthorized access, malware deployment, data exfiltration, scope of impact, and investigation timeline. Two specific dates (December 13, 2023 and November 20, 2023) constitute two hard verifiable facts, reaching the QV threshold.

fact: Forensic investigation completed on December 13, 2023

fact: Last confirmed unauthorized activity on November 20, 2023


reasoning: The paragraph describes the composition and function of the IT Steering Committee (strategic planning, discussing cybersecurity threats) and reporting to the Risk Management committee. Applying the person-vs-function test, the content is about what the committee does (its processes and functions), not about individual credentials or qualifications, making this Risk Management Process rather than Management Role. Two named non-generic committees (IT Steering Committee, Risk Management committee) place this at Firm-Specific, but neither counts toward QV.

thinking:
Let me analyze this paragraph.

Content: Describes an IT Steering Committee's composition and function, plus reporting to Risk Management committee.

Category: This is about internal processes and committee structure. The IT Steering Committee is described in terms of what it does (strategic planning, discussing threats, etc.). The IT manager reports to Risk Management committee. This is more about organizational structure for managing cyber risk - could be Risk Management Process or Management Role or Board Governance.

The grammatical subjects are "IT Steering Committee" and "IT manager." These are management-level entities, not the board. The committee's function is described (strategic planning, discussing threats). The IT manager reports to Risk Management committee.

The committee itself is a management-level body made up of senior staff and operations personnel rather than board members, and since the paragraph focuses on what it does functionally rather than individual qualifications, this falls under Risk Management Process. The "IT Steering Committee" is a firm-specific named entity, while "IT manager" is a generic title without cybersecurity specialization.

I'm identifying the named committees here—both the IT Steering Committee and Risk Management committee are non-generic, organization-specific bodies that count as firm-specific facts. The quarterly cadence is just a generic timeframe. Looking at verifiable facts, named committees alone don't meet the QV threshold without supporting details like dates, headcounts, or specific certifications. This points to Firm-Specific at Level 3.

fact: IT Steering Committee (named non-generic committee)

fact: Risk Management committee (named non-generic committee)


reasoning: The paragraph contains an explicit materiality assessment ('have not materially affected nor are they currently expected to materially affect the Bank's business strategy, financial condition or results of operations'), which per Rule 6 is Strategy Integration. The mention of investing 'significant resources' reinforces the strategic/financial framing. No specific dollar amounts, named frameworks, or firm-specific facts are present—boilerplate materiality language.

thinking:
Classify this paragraph.

Materiality assessment + investment mention.

The paragraph makes an explicit materiality assessment ("have not materially affected nor are they currently expected to materially affect... business strategy, financial condition or results of operations") → Strategy Integration per Rule 6.

It also mentions investing "significant resources" but no specific amounts.

Specificity: No named standards, no firm-specific facts from the IS list. Generic boilerplate materiality language.


reasoning: The paragraph discusses cyber risk insurance as a financial mitigation strategy, which is a business/financial consequence of cyber risk — squarely Strategy Integration. However, it names no insurer, no coverage amount, no deductible, and no other specific facts, making it Generic Boilerplate.

thinking:
Classify this paragraph.

Content: mentions cyber risk insurance with a caveat about coverage limits. This is about financial/strategic response to cyber risk.

Category: Strategy Integration (cyber insurance mention)

Specificity: No named insurers, no dollar amounts, no dates, no firm-specific facts. Generic boilerplate.


reasoning: The paragraph primarily describes incident response actions — scope analysis, customer notifications, credit monitoring, law enforcement coordination, and litigation status. While it ends with a materiality statement, the dominant content is about what the company did in response to the incident. The 1.3 million impacted consumers is the only QV-eligible hard fact (one fact → Firm-Specific, not QV).

thinking:
Let me analyze this paragraph from FNF's 10-K filing.

Content: Describes aftermath of a cybersecurity incident - affected systems analysis, customer notifications, 1.3 million impacted consumers, credit monitoring services, law enforcement coordination, lawsuits, and a materiality assessment.

Category: This describes what happened in response to an incident - scope analysis, notifications, remediation actions. But it also ends with a materiality statement. The dominant content is incident response actions (notification, remediation, legal coordination). The materiality statement is one sentence at the end. → Incident Disclosure

Looking at the specificity here, I've got one concrete quantified fact - the 1.3 million potentially impacted consumers. Everything else is vague: lawsuits without names, generic service descriptions like credit monitoring and identity theft restoration, no dates or named firms or tools. That single headcount figure is really the only hard verifiable fact in this disclosure, which puts it at Firm-Specific level.

fact: approximately 1.3 million potentially impacted consumers


reasoning: The paragraph begins with reporting lines (SVP/CITO to Board) but the dominant content describes internal processes: ERM integration, internal audit assessment of controls, Architecture Review Board for new IT initiatives, and PMO monitoring — all about what the company does, not who the person is. Applying the person-vs-function test, removing the CITO title leaves the process descriptions intact. Multiple named internal structures (ERM Committee, ARB, PMO, GLT) provide firm-specific detail, but no hard verifiable facts (dates, dollar amounts, headcounts, named third-party firms) reach the two-fact QV threshold.

thinking:
Let me analyze this paragraph from Cooper-Standard Holdings Inc.

**Content Category:**
This paragraph covers multiple topics. Let me identify the primary focus:
- IT leadership team manages cybersecurity
- SVP/CITO reports to Audit Committee and Board (reporting lines)
- Cybersecurity team reports to GLT
- ERM Committee integration
- Internal audit assesses cybersecurity program
- Architecture Review Board (ARB) reviews IT initiatives
- Project Management Office (PMO) monitors initiatives

The paragraph starts with management reporting lines but quickly shifts to describing processes: ERM integration, internal audit assessments, ARB reviews, PMO monitoring.

The core of this is really about governance structures and oversight mechanisms. While there are reporting lines mentioned, the substance focuses on how processes like ERM integration, internal audit assessments, and the Architecture Review Board function to oversee cybersecurity initiatives. This points toward Risk Management Process as the primary category. Looking at the next chunk, I'm identifying the PMO as another named internal program alongside the ARB. So far I've found four firm-specific facts: the CITO title, ERM Committee, ARB, and PMO. None of these named roles or internal programs count as hard verifiable facts—there are no specific metrics, dates, dollar amounts, or third-party references that would push this toward quantifiable verification. This keeps the firm-specific count at three.

fact: Senior Vice President, Chief Information Technology Officer

fact: Enterprise Risk Management ("ERM") Committee

fact: Architecture Review Board ("ARB")

fact: Project Management Office ("PMO")

fact: Global Leadership Team ("GLT")


reasoning: The Audit Committee is the primary grammatical subject for the majority of the paragraph (oversight role, receiving reports, updates on program efficacy), making Board Governance the dominant category. The CIO's qualifications and team credentials in the final two sentences are subordinate to the board oversight framing. Specificity is Quantified-Verifiable because there are two QV-eligible hard facts: 'over 10 years of experience' and 'over 13 years of relevant experience' (specific durations).

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Audit Committee oversight (Board Governance)
2. CIO's role (Management Role)
3. What the Audit Committee receives - reports on various topics (Board Governance)
4. CIO's experience and team credentials (Management Role)

The grammatical subject shifts. The Audit Committee is the subject for several sentences, but the CIO and their qualifications are also prominent.

Let me assess dominant category. The paragraph starts with Audit Committee oversight, then describes what reports the committee receives (multiple sentences), then shifts to the CIO's experience and team.

Looking at the actual text allocation, most of the content focuses on what the Audit Committee receives and oversees—periodic reports, regular updates from the CIO—with only the final sentences addressing the CIO's background and team support. The Board Governance elements clearly dominate the paragraph's substance. list)
- "over 10 years of experience" - specific number → QV-eligible
- "over 13 years of relevant experience" - specific number → QV-eligible
- "certified cybersecurity professionals" - not named certifications
- "two other public companies" - vague

The experience durations are both quantified and verifiable facts, and the CIO title is firm-specific, so this qualifies as Quantified-Verifiable with at least two eligible data points.

fact: Chief Information Officer (CIO) — cybersecurity-specific title

fact: CIO has over 10 years of experience overseeing cybersecurity teams

fact: Dedicated team with an average of over 13 years of relevant experience


reasoning: The paragraph's primary subject is a management-level committee — the Bank Technology Governance Committee — describing its composition (CRO, CIO), its cybersecurity responsibilities (approving policies), and the reporting it receives from the director of information security. This is about management's organizational structure for cybersecurity oversight, fitting Management Role (management committees responsible for cybersecurity). It is not about the board (this is explicitly a management-level committee) nor about specific processes/tools/frameworks (Risk Management Process). Specificity is Firm-Specific: the named non-generic committee and cybersecurity-specific titles (CIO, Director of Information Security) are IS-list facts, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named firms/tools) are present.

thinking:
Let me analyze this paragraph.

The paragraph describes the Bank Technology Governance Committee - a management-level committee. It describes its composition (senior leadership including CRO and CIO), its responsibility (approving policies for cybersecurity program), and what reporting it receives from the director of information security.

Category: This is about a management committee's role and composition. The grammatical subject is the committee, which is a management-level committee (not a board committee). This describes management's role in cybersecurity oversight - reporting lines, committee structure. This fits Management Role.

Wait - let me reconsider. The person-vs-function test: is this about the person or the function? This is about a committee structure and what it does (approves policies, receives reporting).

The codebook confirms Management Role covers "management committees responsible for cybersecurity," and the committee itself with its composition and reporting structure is clearly the focus here, not processes or tools. So Management Role is the right fit.

Now checking specificity - I see the Bank Technology Governance Committee is a named, non-generic committee, and while the CRO is a generic C-suite title, both the CIO and director of information security are cybersecurity-specific roles. That gives me multiple firm-specific facts to work with.

Looking at whether any of these qualify as Quantifiable Value facts - I need specific dates, dollar amounts, headcounts, named third-party firms, products, tools, certifications, or years of experience. None of those are present here, so this is Firm-Specific at level 3.

fact: Bank Technology Governance Committee (named non-generic management committee)

fact: Chief Information Officer (cybersecurity-specific title)

fact: Director of Information Security (cybersecurity-specific title)


reasoning: The paragraph describes what the Information Security Department does — day-to-day risk management, processes and procedures, developing control standards, preserving CIA of IT assets. Applying the person-vs-function test: removing the department name, the paragraph still describes generic cybersecurity processes. No named frameworks, no specific certifications, no dates, no named tools/firms, no headcounts — 'variety of technical certifications' and 'continuing education' are vague. 'Information Security Department' is a standard department name, not a firm-specific composition or cybersecurity-specific title from the IS list.

thinking:
Let me analyze this paragraph.

Content: Describes an "Information Security Department" - its composition, responsibilities, certifications, and what it does (day-to-day management, processes, protective measures, developing standards/guidelines/procedures).

Category: This is about what the department DOES - processes, procedures, protective measures, control standards. The person-vs-function test: if I remove the department name, it still describes processes and activities. → Risk Management Process.

Specificity: Let me check for specific facts.
- "Information Security Department" - this is a named internal department, but is it a specific fact? It's somewhat like a named team.

But looking closer, everything here is generic - no named frameworks, no specific certifications listed, no dates, tools, or firms mentioned, and no cybersecurity-specific titles like CISO. Even "Information Security Department" is pretty standard terminology. The reference to "Legal, Compliance, and Finance" in the IS list shows that specific department compositions would be named explicitly, but this paragraph just describes generic functions and vague qualifications without concrete details. a team. "Information Security Department" is just a single department name, and it's a fairly standard name.

Actually, I think "dedicated Information Security Department" is somewhat firm-specific - it tells you this company has a dedicated department. But looking at the IS/NOT lists carefully, I don't see generic department names on either list explicitly. It's not a cybersecurity-specific title (CISO, etc.), not a named committee, not a named tool/firm/date.

I'd say this is Generic Boilerplate - no named standards, no specific facts from the IS list. Everything described is generic processes that could apply to any company.

Wait - "Information Security Department" - is this a named team? The IS list says "Specific team/department compositions." But the example is "Legal, Compliance, and Finance" - meaning the specific makeup of who's on the team. Just naming "Information Security Department" isn't really a composition, it's just a department name. And it's a very standard one, so this falls under Generic Boilerplate.


reasoning: The Board and Audit Committee are the grammatical subjects providing oversight and receiving reports, making this Board Governance. The paragraph names cybersecurity-specific roles (CTO, CISO) which are IS-list facts triggering Firm-Specific, but no QV-eligible hard facts (named roles don't count toward QV; 'quarterly' is a generic cadence).

thinking:
Let me analyze this paragraph.

Content: Board/Audit Committee oversight, receives reports from CTO and CISO quarterly, topics covered, timely incident reporting.

Category: The Board/Audit Committee is the grammatical subject performing the primary action (provides oversight, receives presentations). This is Board Governance.

Specificity: Let me check facts:
- CTO and CISO are cybersecurity-specific titles → IS list items
- "quarterly" is generic cadence → NOT list
- "Audit Committee" → NOT list (generic)
- The topics listed are generic practices

IS facts: CTO, CISO (cybersecurity-specific titles)

Firm-Specific: Yes, because it names the CISO and CTO roles which are on the IS list. No quantifiable metrics like dates, dollar amounts, or headcounts present, so this doesn't qualify as QV.

fact: Chief Technology Officer (CTO)

fact: Chief Information Security Officer (CISO)


reasoning: The paragraph primarily describes incident response actions — scope analysis, customer notification, credit monitoring services, coordination with law enforcement, and related lawsuits — all of which are post-incident narrative. The closing materiality statement is subordinate to the dominant incident response content. Specificity is Firm-Specific: the 1.3 million impacted consumers is one QV-eligible quantified fact, but no second hard verifiable fact (no specific dates, named firms, or dollar amounts in this paragraph) prevents reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph from FNF's 10-K filing.

Content: Describes aftermath of a cybersecurity incident - notification of 1.3 million consumers, remediation services, lawsuits, and a materiality assessment.

Category: This describes incident response actions (notifications, credit monitoring, coordination with law enforcement) AND includes a materiality assessment. The dominant content is about what happened in response to the incident - notifications, services provided, lawsuits. But there's also a materiality disclaimer at the end.

The paragraph describes response actions taken after an incident (scope analysis, customer notification, credit monitoring, lawsuits) - this is Incident Disclosure. The materiality statement at the end is subordinate.

Looking at the tiebreaker rules, this clearly falls under Incident Disclosure since it describes the response actions and scope of the incident rather than just discussing financial impact. The specific number of 1.3 million potentially impacted consumers is quantified, though the language around lawsuits and credit monitoring is fairly standard incident disclosure boilerplate without named firms or specific dates.

So I'm down to one verifiable fact here—the 1.3 million headcount—which makes this Firm-Specific.


reasoning: The paragraph describes the company's process for maintaining cybersecurity workforce competency — training programs, industry group participation, and certification programs. The person-vs-function test points to Risk Management Process: this is about the team's collective training function, not a specific individual's background. Multiple named industry organizations (FS-ISAC, ABA, Mid-Sized Banking Coalition) and numerous named certifications (GIAC family, CompTIA Security+, CISSP) provide well over two hard verifiable facts, reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes cybersecurity personnel training, certifications, industry group participation. This is about the qualifications and professional development of cybersecurity staff.

Category: This is about the personnel's qualifications and certifications - but it's about the team broadly, not a specific person. It describes training processes and certification programs. The person-vs-function test: this is about the function/program of training and professional development, not about a specific individual's background. It describes what the company does to maintain cybersecurity knowledge. → Risk Management Process.

Wait, but it lists specific certifications held by personnel. The codebook says Management Role is about specific persons - their name, qualifications, career history.

Actually, looking more closely at the specific certifications and industry groups mentioned - CERT Insider Threat Program Manager, GIAC Information Security Professional, GIAC Security Leadership, GIAC Continuous Monitoring, GIAC Certified Forensic Analyst, CompTIA Security+, ISC2 CISSP, plus FS-ISAC, American Bankers Association, and Mid-Sized Banking Coalition of America - these are concrete, named qualifications and organizations. These named certifications are QV-eligible facts.

fact: FS-ISAC

fact: American Bankers Association

fact: Mid-Sized Banking Coalition of America

fact: CERT Insider Threat Program Manager certification

fact: GIAC Information Security Professional certification

fact: GIAC Security Leadership certification

fact: GIAC Continuous Monitoring certification

fact: GIAC Certified Forensic Analyst certification

fact: CompTIA Security+ certification

fact: ISC2 CISSP certification


reasoning: The paragraph describes the company's internal security monitoring, event correlation, escalation procedures, and ERM integration — all internal cybersecurity processes. No named frameworks, no cybersecurity-specific leadership titles from the IS list, and no hard verifiable facts appear. 'CSIRT analysts' is a standard industry term (not a unique program identifier), 'Leidos enterprise networks' is a company self-reference, and the described practices (monitoring, logging, escalation levels) are common security operations activities found on the NOT list.

thinking:
Let me analyze this paragraph from Leidos Holdings' 10-K Item 1C filing.

The paragraph describes internal security monitoring processes - devices, applications, CSIRT analysts, escalation levels, ERM integration. This is about the company's own internal cybersecurity processes.

Person-vs-function test: CSIRT is mentioned but as a team receiving notifications, not about any person's credentials. This is clearly about processes/tools/methodology.

Content category: Risk Management Process

Specific facts:
- "CSIRT analysts" - this is a named internal team (Computer Security Incident Response Team). Is this firm-specific? Let me check...

CSIRT is a standard industry term rather than a unique program name, so it doesn't qualify as a distinguishing identifier. "Leidos enterprise networks" is a company self-reference that belongs on the NOT list. The paragraph outlines common practices like monitoring, logging, escalation, and correlation without referencing any named frameworks, specific tools, dates, dollar amounts, or named roles from the IS list. Let me reconsider whether this content actually contains any firm-specific information.


reasoning: The paragraph does not itself make a materiality conclusion — it says 'We describe whether and how risks... have materially affected... under the headings [X, Y, Z] included as part of our risk factor disclosures in Item 1A... which disclosures are incorporated by reference herein.' This is a cross-reference that uses materiality framing language but defers the actual substantive assessment entirely to Item 1A. Per the codebook's distinguishing test: 'does the paragraph make a substantive claim about cybersecurity's impact on the business? If yes → Strategy Integration. If it only points elsewhere → None/Other.' This paragraph only points elsewhere. None/Other always receives Generic Boilerplate.

thinking:
This paragraph contains a materiality assessment framing ("whether and how risks from identified cybersecurity threats... have materially affected or are reasonably likely to materially affect us, including our business strategy, financial condition, or results of operations") but then immediately redirects to specific risk factor headings in Item 1A.

The key question: is this Strategy Integration or None/Other?

Per the codebook: "A cross-reference to Risk Factors appended to a materiality assessment does not change the classification." And "does the paragraph make a substantive claim about cybersecurity's impact on the business? If yes → Strategy Integration."

The critical issue is that this paragraph doesn't actually reach a materiality conclusion—it just says "we describe whether and how risks have materially affected us" and then points to Item 1A for the details. It's using materiality language as a framing device but isn't itself claiming that risks have or haven't materially impacted the company. The actual substance lives in the cross-referenced sections, not here.

So this is really a pure cross-reference dressed up in SEC-required language, with no substantive assessment of its own. I'm classifying it as None/Other with Specificity 1, since the risk factor headings are just section titles. These are just cross-references pointing to Item 1A without making any substantive claims about materiality, so they fall into None/Other. The codebook is clear: a pure cross-reference with no materiality conclusion gets that classification, and since there's no actual determination stated here—just a pointer to where the information lives—Generic Boilerplate is the right specificity rating.