reasoning: The paragraph opens with an explicit materiality assessment ('did not have a material impact on our business strategy, results of operations or financial condition') and closes with forward-looking financial risk language, framing the paragraph's primary purpose as a strategic impact disclosure. While the cybersecurity committee description is substantive, it serves the narrative of how the company responded strategically to past incidents. The cybersecurity committee (a named non-generic committee) and its specific role composition are firm-specific facts but none are QV-eligible hard verifiable facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Past incidents + materiality assessment ("experienced various types of cyber-attack incidents... did not have a material impact on our business strategy, results of operations or financial condition") → Strategy Integration
2. Risk management response ("implement new controls, governance, technical protections") → Risk Management Process
3. Cybersecurity committee composition ("cybersecurity committee composed of EVP of Technology, Director of IT, General Counsel") → Could be Management Role or Board Governance... but this is a management committee, not a board committee → Management Role
4. Committee meeting cadence and reporting ("meets quarterly to review incidents, reports to CFO") → Management Role

5. Forward-looking risk language ("may incur substantial costs") → Strategy Integration/boilerplate

What's the dominant category? The paragraph opens with a materiality assessment, then describes process improvements and committee structure. The cybersecurity committee with its specific composition and quarterly review cadence is quite prominent, but the materiality statement frames the whole discussion. Looking at the distribution, I've got a materiality assessment, process improvements, and management committee details spread across roughly equal weight.

The committee description is detailed and specific, but the paragraph's framing—opening with what didn't materially impact the business and closing with forward-looking risk language—suggests Strategy Integration is the dominant lens. The committee structure is really supporting evidence for how they're managing the risk strategically.

Now I'm checking which roles qualify as specific cybersecurity positions. The Cybersecurity Committee itself is named and on the list, but the Executive Vice President of Technology is more of a general tech leadership role, and the Director of Information Technology falls into the generic IT category. The General Counsel isn't cybersecurity-specific either.

However, the specific composition of this committee—pairing the EVP of Technology with the Director of IT and General Counsel—does constitute a named team composition, which qualifies as firm-specific. There aren't any hard verifiable facts like dates or dollar amounts, so this lands as Firm-Specific based on the committee structure alone.

fact: cybersecurity committee

fact: committee composed of Executive Vice President of Technology, Director of Information Technology, and General Counsel


content_category: Board Governance

category_confidence: high

specificity_confidence: high

reasoning: The Board of Directors and board committees (Nominating and Governance, Audit Committee) are the grammatical subjects throughout, describing their oversight of cybersecurity risks — classic Board Governance. No firm-specific facts remain after filtering: 'Nominating and Governance Committee' and 'Audit Committee' are standard board committees at public companies, and 'quarterly' is a generic cadence on the NOT list.

provider: anthropic

generationId: agent-sdk

stage: benchmark

thinking:
Let me analyze this paragraph.

Content: Board of Directors oversees enterprise risk management. Nominating and Governance committee receives quarterly updates on risk management including cybersecurity. Board oversees cyber risks through Audit Committee reports, which monitors incidents and management's response.

Category: Board Governance - the Board and board committees are the grammatical subjects throughout. This is about board/committee oversight of cyber risk.

Specificity: Let me check for specific facts.
- "Nominating and Governance committee" - this is a named non-generic committee (it's not just "Audit Committee"). Actually, wait - is "Nominating and Governance Committee" generic? Most public companies have one.

Looking at the IS list, it excludes standard committees like Audit Committee, and the non-generic examples are cybersecurity-specific ones like Technology Committee or Cybersecurity Committee. Both the Nominating and Governance Committee and Audit Committee mentioned here are standard governance committees, not specialized cyber oversight bodies, so neither would count as a specific named committee for this purpose. The codebook clarifies that named committees like Technology, Cybersecurity, Risk, and ERM qualify as specific, but standard committees like Audit and Nominating and Governance don't. Since the Nominating and Governance Committee falls into that standard category, I'm classifying this as Generic Boilerplate.


content_category: Management Role

category_confidence: medium

reasoning: The paragraph identifies which management roles are involved in cybersecurity risk management, listing a specific team composition of seven named roles. While the first sentence describes functions (assessing, managing, ERM integration, incident response), the core disclosure purpose is identifying WHO in management is responsible — the specific team composition is the distinguishing content. The named team composition (Head of Security, Head of Global Privacy, Head of Engineering, etc.) is firm-specific, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, tools) are present beyond one cybersecurity-specific role.

thinking:
Let me analyze this paragraph.

Content: Describes management team's involvement in cybersecurity risk assessment and management, lists specific roles involved, mentions escalation to Audit Committee.

Category: This is about management's role in cybersecurity. The paragraph lists who is involved but focuses on what management DOES (assessing, managing, hiring, preparing, responding, determining materiality). Let me apply the person-vs-function test: if I remove the role titles, the paragraph still describes processes (assessing risks, ERM integration, incident response, escalation). However, the middle sentence is entirely about WHO is involved - listing specific roles.

The core purpose here is identifying which management roles handle cybersecurity oversight. While the paragraph describes various functions these roles perform, the primary disclosure is really about establishing WHO in the organization is responsible for managing cyber risk. Looking at the remaining roles, the Chief Business Officer and General Counsel are generic titles, while the CFO appears on the exclusion list. The "Head of Security" designation is cybersecurity-specific, which pushes this toward Firm-Specific classification. The disclosure is really about the specific team composition itself—listing out these particular roles and their responsibilities—which qualifies as firm-specific information. There's no second QV-eligible fact here since named roles and team compositions don't meet that threshold, and there are no dates, amounts, or certifications involved. This lands at Firm-Specific (3).

fact: Head of Security

fact: Team composition: Head of Security, Head of Global Privacy, Head of Engineering, Head of Enterprise Technology & IT, Chief Business Officer, CFO, General Counsel


reasoning: The paragraph is primarily about the CISO as a person — their title, reporting line, degree, certifications, and years of experience. The first sentence is generic, but the dominant content is the person's qualifications. Multiple QV-eligible hard facts: named certifications (ISC2, IAPP), specific years of experience (thirty years), yielding 3+ verifiable facts.

thinking:
Let me analyze this paragraph.

Content: Describes management's approach, then focuses on the CISO - their title, reporting line, education, certifications, and experience.

Category: The first sentence is generic management/RMP. But the bulk of the paragraph is about the CISO as a person - their title, reporting structure, degree, certifications, experience. This is clearly Management Role (person-vs-function test: it's about who the person is).

Specificity: Let me count facts:
- CISO title (cybersecurity-specific role) → IS list
- "Vice President of Cybersecurity" → named role

- Reports to EVP and Chief Innovation Officer → reporting line
- Master of Science degree in Cybersecurity Operations → specific degree
- ISC2 and IAPP certifications → named credentials
- Over thirty years of experience → specific duration

So I've got three hard verifiable facts here: the two named certifications and the specific years of experience. That puts this in Quantified-Verifiable territory.

fact: CISO title (Vice President of Cybersecurity)

fact: Reports to Executive Vice President and Chief Innovation Officer

fact: ISC2 certification

type: quantified

fact: International Association of Privacy Professionals certification

fact: Over thirty years of leadership experience


content_category: Third-Party Risk

reasoning: The paragraph's central topic is the cybersecurity risk posed by third-party service providers — their data handling, the company's limited ability to monitor them, and the lack of assurance against vendor compromise. No named frameworks, vendors, tools, dates, or any facts from the IS list appear; all language is generic and transferable to any company.

thinking:
Let me analyze this paragraph.

Content: Discusses reliance on third-party service providers, onboarding/monitoring processes for vendors, limitations in monitoring vendor cybersecurity. Central topic is vendor/third-party risk.

Category: Third-Party Risk - the entire paragraph is about oversight (or lack thereof) of external parties' cybersecurity.

Specificity: No named frameworks, no named vendors, no specific facts from the IS list. Generic language throughout - "third-party service providers," "best practices," "onboarding and monitoring processes." → Generic Boilerplate (1)


reasoning: The paragraph is about the person filling the cybersecurity leadership role — describing who they are (an 'informational technology consultant'), what they are responsible for, and their qualifications (25 years of experience). While there is some generic process language ('assess and help prepare us to address cybersecurity risks'), the primary communicative purpose is identifying the role holder and their credentials, satisfying the person-vs-function test for Management Role. Specificity is Firm-Specific: 'over 25 years of experience' is one quantified fact (specific duration), but only one QV-eligible hard fact, so it does not reach Quantified-Verifiable. The role title 'informational technology consultant' is not on the IS list of cybersecurity-specific titles (CISO, CTO, CIO, etc.), so it does not contribute an additional specific fact.

thinking:
Let me analyze this paragraph.

The paragraph describes an "informational technology consultant" - their role in overseeing cybersecurity strategy and their experience (25 years). This is about the person - their responsibilities and qualifications.

Person-vs-function test: The paragraph tells us about who this person is (IT consultant, 25 years experience) and what they're responsible for. If I remove the person references, there's some generic process language ("assess and help prepare us... to address cybersecurity risks") but it's thin. The primary content is about the role holder and their qualifications.

Content category: Management Role - the paragraph identifies the cybersecurity leadership role and provides credentials (25 years experience).

The title "informational technology consultant" is generic and doesn't match standard cybersecurity leadership titles like CISO or CIO. The 25 years of experience is a specific number that could qualify as a QV fact, but I need at least two QV-eligible facts for it to count, and I'm only seeing this one concrete detail. I'm checking whether "informational technology consultant" qualifies as a cybersecurity-specific title from the approved list, and it doesn't—it's too generic. Since I only have one verifiable fact (the 25 years of experience, which counts as a specific duration on the IS list), this doesn't meet the two hard facts needed for QV eligibility, so it falls into Firm-Specific classification.

fact: over 25 years of experience in information technology


content_category: Risk Management Process

reasoning: The paragraph describes management committee structure, meeting cadence, and oversight activities for cybersecurity risk management. While it names CISO, CIO, and multiple committees, the person-vs-function test points to Risk Management Process: the substantive content is about what these committees do (oversight, governance, risk management strategy, monitoring, incident response coordination) rather than the individuals' credentials or backgrounds. Multiple named non-generic committees and cybersecurity-specific roles make it Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, headcounts, named firms/tools) reach the two-fact threshold.

thinking:
Let me analyze this paragraph from Northwest Bancshares' 10-K filing.

Content Category: This paragraph describes management committees (IT Steering Committee, Operational Risk Management Committee), their composition, meeting cadence, and reporting to the board. The primary focus is on the management structure and processes for cybersecurity oversight. The grammatical subjects are the committees and the CISO. It's describing organizational structure and processes rather than individual credentials.

The person-vs-function test: The paragraph mentions CIO, Chief Operational Risk Management Officer, and CISO, but describes what the committees DO (oversight, governance, meetings, reporting).

So the core content is about management committee structure and processes—specifically how the IT Steering Committee and Operational Risk Management Committee are organized, who chairs them, how often they meet, and how the CISO reports up to the board's Innovation and Technology Committee. This is fundamentally about governance processes and organizational hierarchy rather than individual qualifications. about organizational structure and what these committees actually do - their oversight activities and governance responsibilities. The reporting line to the board is mentioned but isn't the main focus. I'm settling on Risk Management Process because the paragraph emphasizes the committees' functions and processes rather than the people filling those roles.

Now I'm checking what specific facts are present to evaluate whether this qualifies for QV eligibility. I see named roles like CISO and CIO, plus specific committee names like the Information Technology Steering Committee and Operational Risk Management Committee. The text also mentions meeting cadences - monthly and quarterly. But according to the codebook, named roles and named committees don't count toward QV, and generic cadences like those don't either. So there aren't actually any QV-eligible facts here.

This is clearly Firm-Specific because of the multiple IS facts - the cybersecurity-specific titles and the named committees - but it doesn't meet the QV threshold since there are no specific dates, dollar amounts, headcounts, named third-party firms, or named products mentioned.

fact: Operational Risk Management Committee

fact: Chief Information Officer chairs IT Steering Committee

fact: Chief Information Security Officer

fact: Innovation and Technology Committee (board committee)


reasoning: The paragraph describes the company's internal cybersecurity program structure (six key areas), incident response process with a firm-specific priority classification system (Levels 1-5), and escalation procedures — all internal process content. The Directors Risk Committee mention is subordinate to the process description. Multiple firm-specific facts (named program, named team, named non-generic committee, specific classification system) but no QV-eligible hard facts (no dates, dollar amounts, headcounts, named third-party firms, or named tools).

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

Content: Describes their cybersecurity program structure (six key areas), Corporate Security Group's role, incident response with priority levels 1-5, reporting to Directors Risk Committee, and incident management process.

Category: This is primarily about the company's internal cybersecurity processes - risk assessment, incident response planning, program structure. The mention of Directors Risk Committee is subordinate to the process description. → Risk Management Process

Specific facts:
- "Cybersecurity Risk Management and Strategy, Governance, and Incident Disclosure Program" - named internal program with specific name

- "Corporate Security Group" - named internal team
- "Directors Risk Committee" - named non-generic committee (not just "Audit Committee")
- Priority Level 1-5 incident classification system - firm-specific detail
- Six key areas enumerated - firm-specific program structure

QV check: Do I have TWO or more hard verifiable facts (dates, dollar amounts, headcounts, named third-party firms, named tools/products, named certifications)? No dates, dollar amounts, headcounts, third-party firms, tools, or certifications mentioned. The internal program and committee names are firm-specific but don't meet QV criteria.

So: Firm-Specific (3 named internal elements but no QV-eligible facts).

fact: Named internal program: Cybersecurity Risk Management and Strategy, Governance, and Incident Disclosure Program

fact: Corporate Security Group manages incident response and business continuity

fact: Directors Risk Committee (non-generic committee receiving Level 4-5 incident reports)

fact: Priority Level 1 (low) to Level 5 (high) incident classification system


reasoning: This paragraph describes an internal incident response process step (immediate assessment of nature, scope, and impact). While it mentions the company name and 'sensitive patient data,' company self-references are not specific facts per the codebook, and 'patient data' is generic domain context. The paragraph is about the function/process, not a specific incident or person.


reasoning: The paragraph describes the cybersecurity oversight chain from a Co-President up through the Audit Committee to the Board of Trustees. While the Co-President is mentioned, their content is functional (develops strategies, implements controls, reports) rather than personal (no credentials, background, or qualifications), so the person-vs-function test points away from Management Role. The Audit Committee's oversight role—reviewing enterprise risks, having primary responsibility for ERM oversight—occupies the dominant portion of the paragraph, making Board Governance the best fit. No cybersecurity-specific titles (Co-President is a general corporate title, not on the IS list), no named frameworks, and no firm-specific facts yield Generic Boilerplate.

thinking:
Let me analyze this paragraph from Pebblebrook Hotel Trust's 10-K filing.

Content: Describes cybersecurity risk management with a Co-President responsible, reporting to Audit Committee, board oversight structure.

Category analysis:
- Mentions "Co-Presidents" managing cybersecurity risk - this is about management role
- But also heavy on Audit Committee oversight and Board structure
- The paragraph covers both management and board governance

The grammatical subjects shift: "One of our Co-Presidents" does things (develops strategies, implements controls, reports), then "Audit Committee" reviews and discusses, then "chair of Audit Committee" may report to Board.

Looking at the structure more closely, the Co-President carries the operational weight—they're the ones actively developing strategies and implementing controls—while the Audit Committee's role is more supervisory. The paragraph is roughly balanced between management action and board oversight, but the substance leans toward what management actually does. report to the Audit Committee on cybersecurity matters) versus board oversight (the Audit Committee's role in reviewing and overseeing). The paragraph's primary purpose is explaining the governance structure and oversight chain, which leans toward Board Governance, but the Co-President's functional responsibilities are also central. Given that both elements are substantial, I'll apply the tiebreaker: the paragraph emphasizes what the Co-President does and how they fit into the oversight structure, making Management Role the better classification. report). It's functional. So it's NOT Management Role by that test.

The Audit Committee oversight is Board Governance. The functional description of what the Co-President does could be Risk Management Process, but it's quite high-level.

I think Board Governance is the best fit since:
- The Audit Committee oversight is a major component
- The reporting chain (Co-President → Audit Committee → Board) is governance structure
- The Co-President is described functionally, not personally

Specificity:
- "Co-Presidents" - this is not a cybersecurity-specific title (it's a general corporate title)
- "Audit Committee" - generic, on the NOT list
- "Board of Trustees" - generic governance
- "at least annually" - generic cadence
- No named frameworks, no specific dates, no specific facts from the IS list

Co-President isn't a cybersecurity-specific title like CISO or CIO would be—it's just a standard corporate leadership role. Combined with the lack of any named frameworks or specific details, this reads as generic boilerplate.


reasoning: The paragraph describes internal cybersecurity processes—vulnerability scanning, threat intelligence feeds, and hardware/software assessment—with third-party providers mentioned as one component assisting the company's own program (not as the central topic of vendor oversight). No named frameworks, tools, firms, dates, or other specific facts are present, making this Generic Boilerplate.

thinking:
Classify this paragraph.

The paragraph describes internal cybersecurity processes: vulnerability scans, threat intelligence feeds, and use of external service providers to assess systems. The mention of third parties is as a component of the internal program, not as the central topic of vendor oversight.

Content category: Risk Management Process (describes internal processes - vulnerability scans, threat intelligence, with third parties as one component)

Specificity: No named frameworks, no named roles, no named tools, no dates, no numbers. "External service providers" is generic. "Vulnerability scans," "threat intelligence feeds" are common practices.

This reads as generic boilerplate—standard language without specific details that would distinguish it from typical security documentation.


category_confidence: low

reasoning: The paragraph states that 'the highest levels of management' are kept informed of cybersecurity posture and risks, making management the grammatical subject. However, this is an extremely generic concluding statement with no named roles, no frameworks, no specific facts — it could appear in any company's filing unchanged.

thinking:
Classify this paragraph.

The paragraph says "the highest levels of management are kept abreast of the cybersecurity posture and potential risks facing Bioxytran." This is a generic statement about management being informed. No specific roles, no frameworks, no dates, no specific facts.

It's about management being informed of cybersecurity posture - this could be Board Governance or Management Role. "Highest levels of management" is generic. The paragraph describes ensuring management awareness of cyber risks, which is a governance/oversight statement.

This is quite generic. "Highest levels of management" - not board specifically, not a named role.

The concluding statement about information flow to management leans toward Management Role since it explicitly mentions "management" rather than "board," though the language is ambiguous enough that it could encompass board-level oversight. Either way, it's a generic boilerplate statement with no specific facts whatsoever.


content_category: None/Other

reasoning: This paragraph is generic risk language acknowledging that information systems are vulnerable to cybersecurity threats and 'could potentially' have material impact. It does not make an actual materiality assessment (no 'have/have not materially affected' conclusion), describes no processes, names no roles, and discloses no substantive cybersecurity content — it is a truism applicable to any company. The hypothetical 'could potentially' framing distinguishes it from a Strategy Integration materiality disclaimer.

thinking:
Classify this paragraph.

This is generic language about information systems being vulnerable to cybersecurity threats and potential material impact. Let me analyze:

Content: Says information systems are vital, can be vulnerable, could have material impact. This is generic risk language - no actual materiality assessment (uses "could potentially"), no specific processes, no incident, no board/management details.

Category: This is borderline. It mentions "material impact on our business strategy, results of operations and financial condition" but uses "could potentially" - this is hypothetical risk language, not a materiality assessment. It's not saying "have not materially affected" or "have materially affected." It's just saying threats "could potentially" have impact. This is generic risk language → None/Other.

There's no mention of specific frameworks, roles, dates, or tools—just boilerplate language without any concrete details.


reasoning: This paragraph is essentially Item 1A Risk Factors language restated in Item 1C. Its dominant communicative purpose is warning about hypothetical cybersecurity risks and their potential adverse consequences (customer loss, revenue impact, legal claims, regulatory fines), not describing the company's cybersecurity program, governance, or making a materiality assessment. The brief, generic mention of steps taken ('additional security technologies, internal controls, disaster recovery processes') is entirely subordinate to the risk-warning framing and contains no substantive disclosure. The 'material adverse effect' language is a hypothetical risk warning, not an explicit materiality conclusion about whether risks have affected the business. No named frameworks, roles, dates, or firm-specific facts appear.

thinking:
This is a long paragraph from Item 1C of a 10-K filing. Let me analyze it.

The paragraph discusses cybersecurity risks in general terms - data breaches, security threats, remote work risks, and potential consequences. It's essentially risk factor language that describes what could go wrong. It mentions steps taken (security technologies, internal controls, insurance) but in very generic terms. It also discusses data privacy regulations.

This reads like general risk factor language that was likely cross-referenced from Item 1A. It's describing hypothetical risks and potential consequences rather than describing any specific cybersecurity program, governance structure, or incident.

Content category: This is tricky.

The paragraph is restating risk factor language from Item 1A rather than providing substantive cybersecurity disclosure - it mentions generic protective measures and insurance but the focus remains on potential adverse effects. The language about "material adverse effect on our business" hints at strategy integration, but overall this is boilerplate risk disclosure without specifics on governance, programs, or incidents. I'm torn between Risk Management Process and None/Other. The passage does mention some concrete actions—implementing security technologies, internal controls, network resilience, disaster recovery, remote work upgrades, and insurance—but they're presented so generically that it's hard to tell if this constitutes a real disclosure of cybersecurity practices or just boilerplate risk language. The fact that these activities are buried in a paragraph dominated by hypothetical consequences and potential adverse effects suggests this might still be None/Other, since there's no substantive detail about what these programs actually entail or how they function. with Risk Management Process, but the emphasis on consequences and inadequacy of measures really pushes this toward risk factor territory. The codebook's intent seems to be capturing substantive disclosure about what companies actually do to manage cyber risk, not just warnings about what could go wrong.

I'm going to assign None/Other. This paragraph's primary function is risk disclosure—warning about potential harms and regulatory consequences—not describing the company's actual cybersecurity program or management approach. The generic mention of "steps taken" is too vague and subordinate to the dominant risk warning purpose to constitute substantive disclosure. I'm second-guessing myself on whether this qualifies as Strategy Integration—that category requires explicit materiality assessments, not just hypothetical risk warnings. This is standard boilerplate risk language recycled from Item 1A into Item 1C without any real cybersecurity program details, so I'm settling on None/Other with Specificity 1.


reasoning: The paragraph describes internal cybersecurity processes—redesigning safeguards, addressing gaps, monitoring effectiveness—with the IT consultant mentioned only as attribution for who handles day-to-day management. Applying the person-vs-function test, removing the consultant reference leaves a coherent process description. No named frameworks, cybersecurity-specific titles (an unnamed 'IT consultant' is not on the IS list), dates, or other firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Describes risk assessment follow-up activities (re-design, implement, maintain safeguards, monitor effectiveness) and assigns responsibility to "an IT consultant who reports to management."

Category: The paragraph describes internal processes (safeguards, monitoring) and mentions who is responsible. The person-vs-function test: the paragraph is primarily about what the company does (processes), with the IT consultant mentioned as attribution. Remove "an IT consultant who reports to management" and it still describes processes. → Risk Management Process.

Wait - "an IT consultant" is not a cybersecurity-specific title from the IS list.

The title is too vague and generic—not a recognized cybersecurity role like CISO or CIO—and there are no specific frameworks, dates, numbers, or named organizations to ground this in anything concrete. This reads like generic boilerplate.


reasoning: The paragraph describes the company's own internal approach to cybersecurity (risk-based approach, implemented policies), making it Risk Management Process. It contains no named frameworks, no specific roles, no dates, and no firm-specific details — entirely generic language that could apply to any company.

thinking: Classify this paragraph.


reasoning: The paragraph describes an internal monitoring and vulnerability detection process using a named tool (Coalition Control), making it about the company's own cybersecurity processes. Coalition Control is a named product (one specific fact), reaching Firm-Specific but not Quantified-Verifiable since there is only one hard verifiable fact.

thinking: Classify this paragraph about Coalition Control.

fact: Coalition Control


reasoning: The paragraph's primary content is the reporting/communication structure between the IT Team Director and senior executives (CFO, CEO, General Counsel), describing who meets with whom and the incident escalation chain — this is reporting lines as primary content, pointing to Management Role. However, no cybersecurity-specific titles appear (IT Team Director is akin to 'Director of IT' on the NOT list, and CFO/CEO/General Counsel are generic C-suite), yielding no specific facts after validation filtering.

thinking:
Let me analyze this paragraph.

Content: Describes IT Team Director meeting with CFO/CEO about cyber risks, and incident reporting structure to CFO/CEO/General Counsel.

Category: This is about management's role in cybersecurity oversight - reporting lines and communication structure. The grammatical subject is "IT Team Director" - a management role. But let me apply the person-vs-function test. Is this about the person (credentials, background) or about the function (processes, reporting structure)?

Actually, this describes reporting/communication processes rather than the person's qualifications. The paragraph is about the process of how management stays informed and the incident reporting structure.

The IT Team Director is performing actions related to management oversight, but the core content is really about organizational structure and reporting lines - who communicates with whom about cyber incidents. The codebook does list reporting lines as a Management Role signal, so this seems to fit that category rather than being about the person's individual qualifications.

Looking at the specificity question: "IT Team Director" is a generic IT leadership title, similar to "Director of IT" which the NOT list explicitly excludes as not cybersecurity-specific. The other roles mentioned - CFO, CEO, General Counsel - are also on the NOT list. So while the content describes a management structure, the roles themselves aren't cybersecurity-specific enough to warrant a different classification.


reasoning: The paragraph describes how the Audit and Reserves Committee receives cybersecurity updates from management, detailing briefing cadence (semi-annual, annual reviews) and topics covered. While the VP of IT is the grammatical subject, the communicative purpose is to describe the board committee's oversight mechanism — how it stays informed about cybersecurity risks, incidents, and test results. The 'Audit and Reserves Committee' is a non-generic committee name (unique to this oil & gas company), and 'VP, Information Technology' is a cybersecurity-specific title per the IS list, yielding Firm-Specific. Neither fact is QV-eligible (roles and committees don't count toward the 2-fact QV threshold).

thinking:
Let me analyze this paragraph.

The paragraph describes the VP of IT providing updates to the Audit and Reserves Committee. The primary actor is the VP, Information Technology, but the content is about briefing the board committee. Let me think about category.

The grammatical subject is "The Vice President, Information Technology" - a management role providing updates TO the board committee. But the content is about the reporting relationship and briefing cadence/topics to the board committee.

Per Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). But also "Board oversees... CISO reports to Board quarterly" → Board Governance.

The VP IT is the primary actor, but the focus is really on the board committee's oversight function through these regular briefings. The paragraph emphasizes the reporting structure and what topics get escalated to board-level review, which suggests this is fundamentally about board governance rather than the management role itself. This is a borderline case. Per Rule 2, management roles report to the board, so the VP IT as the primary actor would suggest Management Role. But the person-versus-function test pushes back—this isn't about the VP's qualifications, it's about what the role does in the reporting process, which leans toward Risk Management Process. Though actually, re-reading more carefully, this isn't really about risk management processes themselves; it's about the governance structure and how the board committee receives oversight information. I'm settling on Board Governance because the Audit and Reserves Committee is the entity being informed, and the paragraph's core purpose is describing how the board stays informed about cybersecurity—the VP IT is just the delivery mechanism. Now I need to check the specificity: "Vice President, Information Technology" is a specific title, but is it cybersecurity-specific enough?

—the IS list includes "VP of IT/Security," so this would qualify. "Audit and Reserves Committee" is a named non-generic committee specific to this company (the "Reserves" component signals oil & gas), which also qualifies. However, named roles and named committees aren't QV-eligible, so this lands as Firm-Specific.

fact: Vice President, Information Technology

fact: Audit and Reserves Committee


reasoning: The paragraph describes the CIMT's incident response function — its responsibilities (containment, response, investigation, reporting, recovery), departmental composition, and operating structure. While leadership titles appear (CDO, General Counsel), they serve as attribution for who runs the process; the substantive content is about how the incident response team is structured and what it does, making this Risk Management Process. Multiple firm-specific facts (named program CIMT, specific departmental composition, cybersecurity-specific titles, Governance Committee) support Firm-Specific, but no QV-eligible hard facts (dates, dollar amounts, named third-party firms, tools) appear.

thinking:
Let me analyze this paragraph.

Content: Describes the CIMT (Cyber Incident Management Team) - its responsibilities, composition, leadership structure, and reporting lines.

Category: This is about internal processes - incident response coordination, team composition, and how the team operates. The CIMT is a management team. Let me apply the person-vs-function test. The paragraph describes what the team does (containment, response, investigation, reporting, recovery), its composition (departments), and its leadership structure. It's about the function/process, not about individual people's credentials.

However, there are elements of Management Role (CDO, General Counsel co-leadership, reporting to CEO/board).

The dominant focus here is the team's structure and operational responsibilities - how the CIMT coordinates incident response across departments, who leads it, and what oversight mechanisms are in place. This points to Risk Management Process rather than a specific management role.

Specificity: "CIMT"

Now I'm identifying which elements qualify as IS list items - the specific departmental composition (Communications, HR, IT and Cybersecurity, Legal and Compliance, Risk Management), the Governance Committee as a named oversight body, and the IT Director/Cyber Security title. The General Counsel and CEO are generic C-suite positions, so they don't count toward the IS list threshold.

For quantifiable verification, I don't see any of the required elements like specific dates, dollar amounts, headcounts, named third parties, products, certifications, or years of experience. That rules out QV classification.

With three IS list items present, this qualifies as Firm-Specific.

fact: CIMT (Cyber Incident Management Team) - named internal program

fact: Team composed of Communications, Human Resources, IT and Cybersecurity, Legal and Compliance, Risk Management departments

fact: IT Director, Cyber Security

fact: CDO (Chief Digital Officer) co-leads the CIMT

fact: Governance Committee


content_category: Strategy Integration

reasoning: The paragraph contains an explicit materiality assessment ('have not identified risks... which have materially affected us' and 'reasonably likely to materially affect us'), which per Rule 6 makes it Strategy Integration regardless of the brief ERM integration mention. No named frameworks, roles, dates, or other specific facts — all language is boilerplate materiality disclaimer.

thinking:
Let me analyze this paragraph carefully.

The paragraph has two parts:
1. ERM integration statement - "We consider cybersecurity... within our overall enterprise risk management framework"
2. Materiality assessment - "we have not identified risks... which have materially affected us, but we face certain ongoing cybersecurity risks threats that, if realized, are reasonably likely to materially affect us"

The materiality assessment is the dominant content here. Per Rule 6, any paragraph that explicitly assesses whether cybersecurity risks have "materially affected" the company → Strategy Integration.

Specificity: No named frameworks, no specific facts from the IS list. "Enterprise risk management framework" is generic.

The materiality language itself is boilerplate—it's the standard disclosure language companies use without substantive detail about actual risks or integration.


reasoning: The Board of Directors and Audit Committee are the grammatical subjects throughout, describing their oversight of cybersecurity risk assessment and escalation processes. No firm-specific facts are present — 'Board of Directors' and 'Audit Committee' are on the NOT list, and the descriptions (oversight, risk management, escalation) are entirely generic.

thinking:
Let me analyze this paragraph.

Content: Board and Audit Committee oversight of cybersecurity risk. The grammatical subjects are "Board of Directors" and "Audit Committee" throughout.

Category: Board Governance - clear, the board and its committee are the subjects performing oversight.

Specificity: Let me check the facts:
- "Board of Directors" - generic (NOT list)
- "Audit Committee" - generic (NOT list)
- No named frameworks, no specific dates, no named roles (CISO etc.), no numbers

This is Generic Boilerplate - could apply to any company.


reasoning: The CEO is the grammatical subject performing the primary action (briefing the Audit Committee on cybersecurity risks), making this a Management Role paragraph per Rule 2 ('Management role reports TO the board → Management Role'). However, the paragraph describes the CEO's governance communication function rather than credentials or background, so category confidence is moderate. No IS-list facts are present: CEO is a generic C-suite title, Audit Committee is standard governance, and 'minimum frequency of once per year' is a generic cadence — all appear on the NOT list.

thinking:
Let me analyze this paragraph.

Content: CEO briefs Audit Committee on cybersecurity risks, minimum annually, covering landscape, threats, initiatives, strategies.

Category: The CEO is briefing the Audit Committee. The board committee (Audit Committee) is receiving briefings, but the CEO is the grammatical subject performing the action. This is about the CEO's role in informing the committee - so it's about a management figure's role in cybersecurity oversight.

Wait - the CEO is a generic C-suite title per the NOT list. But the paragraph is about the CEO informing the Audit Committee.

The CEO is the grammatical subject performing the briefing action, and per Rule 2, when a management role reports to the board, that's a Management Role category. The paragraph describes the briefing activity itself—what the CEO does—rather than their credentials or background. This isn't really about a Risk Management Process either; it's governance communication between management and the board committee, specifically the cadence and topics covered.

Looking at the actual category definitions, though, I notice Board Governance explicitly lists "briefing frequency" as a marker, while Management Role focuses on "CISO/CTO/CIO identification, qualifications, reporting lines." The briefing cadence and topics here align more closely with Board Governance oversight, even though the CEO is the grammatical subject.

Since the CEO isn't a cybersecurity-specific role and this is just a small company where the CEO handles cyber oversight, I'm treating this as Management Role based on the CEO being the primary actor describing their governance responsibilities. The content itself—generic C-suite, generic committee, generic annual cadence—contains no specific facts or named frameworks, so this is Generic Boilerplate.


reasoning: The paragraph's primary communicative purpose is introducing the company's cybersecurity risk management processes (confidentiality, integrity, availability of critical systems). The second sentence mentions Board and senior management oversight, but this is a generic framing statement rather than substantive governance disclosure — no specific committee, briefing cadence, or named roles are described. No named frameworks, cybersecurity-specific titles, dates, or other facts from the IS list are present; 'Board of Directors' and 'senior management' are on the NOT list.

thinking:
Classify this paragraph.

Content: Describes having cybersecurity risk management processes, then says oversight is shared by Board and senior management. This is a general introduction to the cybersecurity section. The dominant content is about the existence of a risk management program ("developed and implemented cybersecurity risk management processes"). The second sentence mentions board and management oversight but in a generic way.

Category: Risk Management Process - it opens with describing their processes, and the oversight mention is introductory/generic.

Actually, this is borderline. The first sentence is about RMP, the second is about governance (both board and management). The dominant purpose seems to be introducing their cybersecurity program broadly.

The first sentence clearly establishes the risk management focus, while the second provides generic governance context without specifics. Since there are no named frameworks or concrete details—just standard language about the Board and senior management—this reads as generic boilerplate.


reasoning: The paragraph describes the company's own internal security architecture — data storage, network segmentation, firewall configuration — which are internal cybersecurity controls and processes. AWS RDS is a named product/tool qualifying as a firm-specific fact; however, port 80 is a standard protocol detail, not a second QV-eligible fact, so specificity stays at Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me classify this paragraph.

Content: Describes technical infrastructure - AWS RDS, private network, port 80, firewall setup. This is about the company's own internal security architecture/processes.

Category: Risk Management Process - describes internal security infrastructure and controls.

Specificity:
- "Amazon Relational Database Service (AWS RDS)" - named product/tool ✓
- "port 80" - specific technical detail
- "AWS's firewall" - named service

Named products/tools: AWS RDS is a named product. That's one QV-eligible fact. Port 80 is a technical specification but not really a "named product" - it's a standard port number.

The firewall is part of AWS's broader ecosystem, so I'm really looking at AWS RDS as the only distinct named product here, which gives me one QV-eligible fact and puts this in the Firm-Specific category.


reasoning: This is a pre-operational or shell company that explicitly has not yet commenced operations and has no cybersecurity program in place. The mention of the 'sole executive officer and director' is perfunctory — it acknowledges responsibility without describing any substantive governance, process, or program. Per the SPAC/no-operations rule, the absence of a program is not a description of a program, and incidental mentions of oversight responsibility do not constitute substantive disclosure.

thinking:
Let me analyze this paragraph.

This is a company that hasn't commenced operations yet - likely a SPAC or shell company. Key signals: "sole executive officer," "once the Company commences operations," no cybersecurity expertise, no program described.

This fits the SPAC/shell company pattern from the codebook. The company hasn't started operations, has no cybersecurity program, and the mention of the executive officer is perfunctory. The absence of a program is not a description of a program.

Category: None/Other - This is a shell/pre-operational company with no substantive cybersecurity disclosure. The executive officer mention is perfunctory, and the forward-looking statement about future operations confirms no current program exists.

Since this is a pre-operational shell company with no actual cybersecurity program in place, the specificity rating is generic boilerplate.


reasoning: The paragraph describes the company's own internal security measures — .pem file authentication, SSL encryption, and AWS Shield DDoS protection — making it squarely about internal cybersecurity processes. AWS Shield is a named product/tool (firm-specific), but SSL is a ubiquitous protocol (not firm-specific) and .pem files are a generic technical concept, so only one QV-eligible fact exists, yielding Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes technical security measures - .pem files, SSL encryption, AWS Shield for DDoS protection. These are internal security processes/tools.

Category: Risk Management Process - describes the company's own internal security processes and tools.

Specific facts:
- AWS Shield (named product/tool) - QV eligible
- SSL (Secure Socket Layer) - this is a generic protocol, not a named product/tool per se
- .pem file - generic technical concept

Actually, AWS Shield is a named product (Amazon's DDoS protection service). SSL is a widely-known protocol, more like a standard than a named tool. Let me think...

SSL is too ubiquitous to count as firm-specific—it's essentially a standard that every website implements. AWS Shield, though, is a distinct named service from AWS that qualifies as a specific tool. The .pem file is just a generic technical format. So I'm looking at one QV-eligible fact here, which makes this Firm-Specific.

fact: AWS Shield for DDoS defense


reasoning: The CFO is the grammatical subject performing cybersecurity oversight and reporting to the Board, making this a Management Role paragraph about who is responsible and their reporting line. While CFO is generic C-suite (not a cybersecurity-specific title per the IS list), the named tool 'Coalition management platform' is a firm-specific fact that elevates specificity beyond boilerplate.

thinking:
Let me analyze this paragraph.

Content: CFO oversees cybersecurity day-to-day, uses Coalition management platform, reports to Board.

Category: This is about who manages cybersecurity (CFO) and what they do. The person-vs-function test: it mentions CFO but describes what they do (oversight, uses platform, reports to board). However, CFO is on the NOT list (generic C-suite). The paragraph is about the management role's responsibilities. But CFO isn't a cybersecurity-specific title per the IS list.

Actually, let me reconsider.

The CFO's cybersecurity oversight and board reporting structure is the main point here, which clearly falls under Management Role. Even though CFO is a generic C-suite title, the paragraph is fundamentally describing who's responsible for cybersecurity management and their reporting lines, so the category is Management Role regardless of whether the CFO counts as a firm-specific fact.

Looking at specificity: the CFO and Board are both generic governance terms that don't count, but Coalition management platform is a named product—that's the one firm-specific fact here, making this Firm-Specific (3).

fact: Coalition management platform


reasoning: The paragraph makes an explicit materiality assessment ('did not experience a material cybersecurity incident'), which per Rule 6 classifies it as Strategy Integration even though a cross-reference to Risk Factors is appended. 'December 31, 2024' is a standard fiscal year-end reference, not a cybersecurity-specific date, and no other specific facts are present, so specificity is Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: "Although we did not experience a material cybersecurity incident during the year ended December 31, 2024, the scope and impact of any future incident cannot be predicted. See 'Item 1A. Risk Factors' for more information on our cybersecurity-related risks."

This contains a materiality assessment ("did not experience a material cybersecurity incident") plus a cross-reference. Per Rule 6 and the codebook, a materiality assessment makes this Strategy Integration even with the cross-reference.

Specificity: "December 31, 2024" is a fiscal year end date, but it's standard reporting period language, not a cybersecurity-specific date.

The remainder is just standard boilerplate language.


reasoning: This is generic risk language describing hypothetical consequences of IT compromise (fines, damages, litigation, reputational harm). It contains no substantive cybersecurity disclosure — no process, no governance, no incident, no materiality assessment. It reads like boilerplate risk factor language that could apply to any company.


reasoning: The paragraph's central topic is cybersecurity risk from third-party service providers — exposure to breaches at vendors and the company's intent to monitor those risks. This is vendor risk oversight, not the company's own internal processes. No named frameworks, firms, dates, roles, or other specific facts appear; all language is generic ('service providers,' 'continuously monitor,' 'material financial, operational or reputational impact').

thinking:
Classify this paragraph.

The paragraph discusses risks from third-party service providers and monitoring of those risks. The central topic is vendor/supplier cybersecurity risk.

Content category: Third-Party Risk - the central topic is risks from third-party service providers and monitoring those risks.

Specificity: No named frameworks, no specific facts from the IS list. Generic language throughout - "third-party service providers", "continuously monitor", no named vendors, no specific processes. → Generic Boilerplate.


reasoning: The paragraph's primary content is about WHO is responsible for cybersecurity — the IT and C&RM teams, their members' certifications (CISSP, CISM, CRMA, CRISC), and the oversight/reporting structure among teams. While it touches on functions (establishing policies, oversight, audit), the emphasis on team identity and personnel qualifications makes Management Role dominant. Four named certifications provide multiple QV-eligible hard facts, reaching Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes IT and C&RM teams' responsibilities, their certifications, oversight structure, and internal audit function.

Category analysis:
- Names specific teams (IT, C&RM) and their responsibilities
- Lists certifications held by team members (CISSP, CISM, CRMA, CRISC)
- Describes C&RM oversight of IT
- Internal Audit function reviews and reports to Audit Committee

This is about the management structure and the people/teams responsible for cybersecurity. But let me apply the person-vs-function test. The paragraph describes what the teams DO (establish policies, provide oversight, review activities) but also describes WHO the people are (their certifications). It's a mix.

The certifications are a key detail here—they're establishing credibility and qualifications of the people involved. When I strip away the team names and certifications, what's left is just generic oversight and review processes. So the dominant focus is really on the organizational structure and the qualified people filling those roles, which points to Management Role rather than a process description.

Looking at the specificity markers: the teams are named (Information Technology and Compliance and Risk Management), and there are four specific certifications listed (CISSP, CISM, CRMA, CRISC). These would normally be QV-eligible facts, but the codebook requires that certifications be held by named individuals. Here they're held by unnamed team members generally, so that distinction matters for whether they count as QV-eligible. The certifications are attributed to unnamed team members rather than a specific role like the CISO in the calibration example, but they're still named credentials—CISSP, CISM, CRMA, CRISC—so with four distinct certifications listed, they qualify as quantified-verifiable facts.

fact: Information Technology (IT) team

fact: Compliance and Risk Management (C&RM) team

fact: Certified Information Systems Security Professional (CISSP)

fact: Certified Information Security Manager (CISM)

fact: Certification in Risk Management Assurance (CRMA)

fact: Certified in Risk and Information Systems Control (CRISC)


reasoning: The paragraph describes generic cyber threats facing the company and frames them in terms of potential material adverse business/financial impact ('materially adverse effect on our competitive position, reputation, results of operations, financial condition or cash flows'). While it touches on threat landscape context, its primary communicative purpose is assessing the potential business and financial consequences of cybersecurity risk, placing it in Strategy Integration. However, the materiality language is purely hypothetical ('could have'), not a definitive assessment, keeping confidence moderate. All language is generic boilerplate — no named frameworks, roles, dates, tools, or firm-specific facts.

thinking:
Let me analyze this paragraph from Capitol Federal Financial's 10-K Item 1C filing.

The paragraph describes generic cyber threats (malicious activity, unauthorized access, viruses, phishing) and then discusses potential material adverse impacts. It's essentially risk language about what could happen.

Content category: This is a mix of generic threat landscape description and materiality/impact language. The key question is whether the materiality language at the end constitutes a Strategy Integration materiality assessment.

Looking more carefully: "could have a material adverse impact", "could have a materially adverse effect on our competitive position, reputation, results of operations, financial condition or cash flows" - these are hypothetical/forward-looking risk statements, not explicit materiality assessments.

The language here uses "could have" rather than making a definitive claim about whether incidents "have" or "are reasonably likely to" materially affect the business. This is more generic risk disclosure than the kind of explicit materiality assessment the codebook identifies as Strategy Integration. The paragraph acknowledges having an information security program but doesn't describe any specific governance structure or process, and it doesn't make a clear determination about actual materiality—it's just laying out potential consequences if threats materialize. The language "could have a materially adverse effect" is vaguer than "reasonably likely to materially affect," so I'm reconsidering whether this fits Strategy Integration or falls into more generic risk territory. But the core issue is that the paragraph emphasizes potential business impact—disruption to operations, damage to reputation, financial consequences—which points toward Strategy Integration at Specificity 1, even if the framing is somewhat general. of Strategy Integration, Specificity 1. The paragraph discusses potential material adverse effects on business operations, financial condition, and other consequences from cyber threats. There are no specific facts here—just generic risk language framed around strategic and financial impact.


reasoning: The paragraph frames cybersecurity as part of the company's overall ERM approach and lists 'Governance' as one key area, describing management's oversight and reporting to the board. The primary communicative purpose is describing the structure of the cybersecurity risk management program (ERM integration, key areas), with governance as a component. No specific person, credentials, or named role is identified—just generic 'Management'—so the person-vs-function test points to Risk Management Process. No named frameworks, firm-specific facts, or verifiable details are present.

thinking:
Let me analyze this paragraph.

The paragraph describes management's role in cybersecurity as part of ERM, focusing on governance where management oversees risk mitigation and reports incidents to the board.

Content category: This is about management overseeing cybersecurity and reporting to the board. The grammatical subject is "Management" - they oversee and report. But the content is quite generic - it's describing management's function within ERM.

Actually, looking more carefully: "Management oversees cybersecurity risk mitigation and reports to the board of directors any cybersecurity incidents." The subject is management, describing what management does. But it's very generic - no named roles, no specific people.

I'm trying to determine whether this fits Management Role or Risk Management Process. The paragraph is fundamentally about what management does functionally—overseeing mitigation and reporting—rather than describing a specific person or role. There's no individual named, no credentials mentioned. Even though the codebook includes management committees under Management Role, this paragraph is so generic that it reads more like a description of the governance function itself. The mention of ERM approach and key areas suggests it's framing cybersecurity within a broader risk management structure. The reporting structure points to Management Role since management reports to the board, which matches the codebook pattern. But there's no specific person or named role here—just generic "management"—so this is boilerplate-level specificity with no concrete details like names, frameworks, or dates.

Actually, reconsidering the framing: the paragraph is really describing how cybersecurity fits into their broader enterprise risk management approach, with governance as one component of that system. That makes Risk Management Process the better fit, since the main point is their risk management methodology and its key areas rather than a specific management role. Either way, this is generic boilerplate with no firm-specific facts.


reasoning: The paragraph's primary communicative purpose is board-level oversight of cybersecurity risk — the Board of Directors is the grammatical subject throughout, covering oversight responsibility, briefing cadence, and engagement with management. However, every sentence is aspirational ('We expect that...'), suggesting no current program exists, which lowers category confidence (borderline with None/Other under the SPAC/no-program principle). Specificity is Generic Boilerplate: no named frameworks, no cybersecurity-specific roles, no firm-specific facts — only generic governance language ('Board of Directors,' 'senior management,' 'quarterly') that could apply to any company.

thinking:
This is a forward-looking paragraph from what appears to be a pre-operational or early-stage company. Everything is framed as expectations ("We expect that...") rather than descriptions of existing programs. Let me classify it.

Content: All about board oversight expectations - board responsible for oversight, quarterly updates, periodic conversations. The grammatical subject is primarily the Board of Directors. This is Board Governance.

But wait - everything is aspirational/forward-looking ("We expect"). This could push toward None/Other since there's no actual program in place. However, the codebook says None/Other is for companies that "explicitly state they have no operations, no cybersecurity program." This company doesn't say it has no program - it's describing expected future governance.

The None/Other rules mention "Forward-looking statement disclaimers" as None/Other, but this isn't a disclaimer—it's substantive content about expected governance structure. The SPAC rule says companies that "explicitly state they have no operations" get None/Other, which this company doesn't do. Yet the language "We expect that cybersecurity will become an important part" does suggest they currently have nothing in place.

The codebook is clear though: "Assign None/Other ONLY when the paragraph contains no substantive cybersecurity disclosure content." This paragraph does describe a governance structure, even if aspirational. The question is whether aspirational governance counts as substantive disclosure or whether the lack of current operations disqualifies it.

The SPAC exception is instructive: "The absence of a program is not a description of a program." This company is describing what it expects to do, not what it currently does. Every sentence starts with "We expect." That's essentially a company without a cybersecurity governance program yet, describing what it plans to have.

I'm going with Board Governance since the paragraph's primary purpose is about board oversight of cybersecurity, even if aspirational. The board is the grammatical subject throughout. For specificity, there are no named frameworks or specific facts from the IS list—just "Quarterly" as a generic cadence and "Board of Directors" and "Senior management" as generic terms. That's Generic Boilerplate.


reasoning: The paragraph lists internal cybersecurity practices — patching/updates, software maintenance, employee training, and review of third-party security procedures. While third-party review is mentioned, it is one component among several internal processes, making Risk Management Process the dominant category. No named frameworks, tools, roles, dates, or other IS-list facts are present; 'third-party service' is unnamed, training is generic, and 'Fuel Tech' is a company self-reference (NOT-list item), yielding Generic Boilerplate.

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

This appears to be a fragmented/truncated list of cybersecurity practices. Let me parse what's being described:

1. Deployment of updates and patches
2. Maintaining current versions of major software
3. Use of third-party service for mandatory online training for employees regarding cybersecurity
4. Review of security procedures used by third parties that host or have access to data

This is a mix of internal processes (patching, software maintenance, training) and third-party oversight (reviewing third-party security procedures).

The core of what they're describing is their internal risk management approach—patching systems, keeping software current, training employees, and vetting third-party security practices. There's no mention of specific frameworks, named tools, or dates, just generic descriptions of standard cybersecurity hygiene. I notice there's a reference to "Fuel Tech's data" which seems odd given this is supposedly VIVIC CORP's filing, so that might be extracted text from the wrong source.


reasoning: The paragraph's primary content describes oversight of third-party service providers — security assessments before engagement, ongoing monitoring, and compliance with cybersecurity standards — making Third-Party Risk the dominant category. The trailing materiality sentence ('have not encountered cybersecurity challenges that have materially impaired our operations') is a secondary element that would otherwise be Strategy Integration, but the vendor oversight discussion occupies the majority of the text. No named frameworks, tools, firms, dates, roles, or specific numbers appear; all language is generic and interchangeable across companies.

thinking:
Let me analyze this paragraph.

The paragraph has two parts:
1. Third-party risk management processes
2. A materiality disclaimer at the end

For the first part - it describes vendor oversight processes (assessments before engagement, ongoing monitoring, compliance with standards). This is Third-Party Risk content.

The second part is a materiality disclaimer ("have not encountered cybersecurity challenges that have materially impaired our operations or financial standing") → Strategy Integration.

Which is dominant? The third-party risk discussion takes up most of the paragraph. The materiality statement is one sentence at the end.

So this is Third-Party Risk content, but I'm not seeing any specific details—no named frameworks, tools, dates, firms, numbers, or cybersecurity-specific roles. The language is all generic: "stringent processes," "thorough security assessments," "ongoing monitoring." This is Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity program design, controls, and framework alignment — all hallmarks of Risk Management Process. It names the NIST Cybersecurity Framework, which elevates it to Sector-Adapted, but contains no firm-specific facts (no named roles, tools, dates, or quantified details) beyond that framework reference.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity program design, mentions NIST CSF framework, general language about controls and investments.

Category: Risk Management Process - describes internal cybersecurity processes, framework adoption, program design.

Specificity: Names NIST CSF framework → Sector-Adapted. No firm-specific facts beyond that.

fact: NIST Cybersecurity Framework

type: framework


reasoning: The paragraph describes the company's internal cybersecurity processes — risk assessments, safeguards (MFA, network segmentation, endpoint protection, vulnerability scanning, patch management), and digital-asset-specific controls. All of these are common security practices; no named frameworks, tools, firms, dates, roles, or other facts from the IS list appear. The digital-asset controls (multi-party key controls, segregation of duties, validator monitoring) are sector-common practices, not firm-specific facts.

thinking:
Let me classify this paragraph.

Content: Describes internal cybersecurity processes - risk assessments, safeguards, specific security controls. This is about what the company does internally.

Category: Risk Management Process - describes risk assessment methodology, security controls, monitoring.

Specificity: Let me check for specific facts:
- No named frameworks (NIST, ISO, etc.)
- No named roles (CISO, etc.)
- No named tools or products
- No dates, dollar amounts, headcounts
- No named firms
- Lists common practices: MFA, privileged access management, network segmentation, endpoint protection, vulnerability scanning, patch management

- Digital asset operations mention multi-party key controls and validator monitoring, but these are standard crypto industry practices without naming specific standards or entities.

All of this falls into generic boilerplate - common security practices described without any firm-specific details or named standards.


reasoning: The paragraph describes the company's internal cybersecurity risk management processes — ERM integration, detection of vulnerabilities, notification policies. The Head of Information Security is mentioned as an incidental attribution (who collaborates), not as the subject of credential or background discussion, so the person-vs-function test points to Risk Management Process. 'Head of Information Security' is a cybersecurity-specific title on the IS list, yielding one firm-specific fact but no second QV-eligible hard fact.

thinking:
Let me analyze this paragraph.

Content: Describes integration of cybersecurity into broader risk management, collaboration between risk management team and Head of Information Security, processes for detection, policies for notification.

Category: This is about internal processes - risk assessment, framework integration, monitoring, policies. The Head of Information Security is mentioned but as attribution for who collaborates, not about the person's qualifications. The paragraph is about what the program does. → Risk Management Process

Specificity:
- "Head of Information Security" - this is a cybersecurity-specific title → IS list → Firm-Specific
- No named frameworks, no dates, no dollar amounts, no named tools

- Only one IS-list fact identified, so this rates as Firm-Specific (3)

fact: Head of Information Security


reasoning: The paragraph describes cybersecurity monitoring, email alerting, and network scanning activities performed by an unnamed 'IT Service Provider' as part of the company's security operations. While a third party performs the work, the paragraph describes what the provider does for the company's internal security program (monitoring, scanning, vulnerability identification) rather than imposing requirements ON vendors or describing vendor oversight — making it Risk Management Process per Rule 3. No named frameworks, tools, firms, dates, or cybersecurity-specific roles appear; 'IT Service Provider' is an unnamed entity on the NOT list, and the activities described (monitoring, scanning, alerting) are generic practices.

thinking:
Let me analyze this paragraph.

Content: Describes monitoring, email alerts, scanning - all internal cybersecurity processes performed by an "IT Service Provider." The IT Service Provider is an external party doing the work, but the paragraph describes what they do for the company's cybersecurity program.

Category: This is about monitoring, scanning, vulnerability identification - these are risk management processes. However, the actor is a third-party "IT Service Provider." The question is whether this is Third-Party Risk or Risk Management Process.

Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." The IT Service Provider is performing cybersecurity functions for the company. This isn't about oversight OF vendors or requirements imposed on vendors - it's about what the vendor does as part of the company's security program.

So this is Risk Management Process. Now I'm checking the specificity - there's an unnamed IT Service Provider with no identified frameworks, tools, dates, or firms mentioned. The practices described are generic: monitoring, scanning, email alerts. Since there are no named standards or specific facts from the list, this falls into generic boilerplate.


content_category: Incident Disclosure

reasoning: The paragraph describes an actual cybersecurity incident (fraudulent email leading to an erroneous $0.7M payment) including timing, nature, financial impact, and remediation actions. Two hard verifiable facts—specific date (December 31, 2023) and dollar amount ($0.7 million)—qualify it as Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Describes a specific cybersecurity incident - fraudulent email leading to erroneous $0.7M payment, followed by remediation with outside consultant.

Category: Incident Disclosure - describes what happened, when, scope, and response actions.

Specific facts:
- "year ended December 31, 2023" - specific date
- "$0.7 million" - dollar amount
- "term loan payment being initiated in error to an account provided in a fraudulent email" - incident details

QV check: specific date (December 31, 2023) + dollar amount ($0.7 million) = 2 hard verifiable facts → Quantified-Verifiable

fact: Year ended December 31, 2023

fact: $0.7 million term loan payment


reasoning: The Audit Committee is the grammatical subject throughout — it receives incident information and discusses cybersecurity risk management. This is board-level oversight activity. The CSO title is a cybersecurity-specific role (IS list), making this Firm-Specific, but all other details (Audit Committee, quarterly cadence, generic topic list) are on the NOT list, so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee receives information about incidents, discusses cybersecurity risk management quarterly with the CSO. Topics include various cybersecurity matters.

Category: The Audit Committee is the grammatical subject performing actions (receives information, discusses). This is Board Governance.

Specificity: Let me check facts:
- "Audit Committee" - NOT list (generic)
- "quarterly" - NOT list (generic cadence)
- "CSO" (Chief Security Officer) - This is a cybersecurity-specific title, similar to CISO. It's on the IS list as a cybersecurity-specific title. That's one firm-specific fact.

- No named frameworks, dates, dollar amounts, or named firms present.

So one IS fact (CSO) → Firm-Specific (3). Only one hard fact here, so this doesn't meet the QV threshold.

fact: CSO (Chief Security Officer) — cybersecurity-specific title


reasoning: The Audit Committee is the grammatical subject overseeing cybersecurity risk, with management reporting to it — classic Board Governance. No firm-specific facts appear: 'Audit Committee' is generic governance, 'quarterly' is a generic cadence, and 'management' is not a cybersecurity-specific role. Everything here could apply to any public company.

thinking:
Let me analyze this paragraph.

Content: Board/Audit Committee oversight of cybersecurity, quarterly reporting from management to Audit Committee. The Audit Committee is the primary subject performing oversight. This is Board Governance.

Specificity: Let me check facts.
- "Audit Committee" — generic, on the NOT list
- "quarterly basis" — generic cadence, on the NOT list
- "management provides reports" — generic

No named frameworks, no firm-specific facts from the IS list. No cybersecurity-specific titles (just "management"). This is Generic Boilerplate.


reasoning: The paragraph describes an actual cybersecurity incident — a fraudulent email leading to an erroneous wire transfer — along with its timeline, financial impact, and remediation actions taken. While the $0.7M loss is a financial figure, it is embedded within the incident narrative describing what happened and the response, making the dominant purpose Incident Disclosure rather than Strategy Integration. Two QV-eligible hard facts: specific date (December 31, 2023) and dollar amount ($0.7 million).

thinking:
Let me analyze this paragraph.

Content: Describes a specific cybersecurity incident (fraudulent email leading to $0.7M loss), plus remediation actions taken afterward.

Category: This describes what happened (fraudulent email, erroneous payment), the financial impact ($0.7M loss), and remediation steps. The paragraph primarily describes the incident narrative - what happened, when, and response actions. The financial impact is part of the incident description. → Incident Disclosure

Specificity: Let me count hard verifiable facts:

- "year ended December 31, 2023" - specific date
- "$0.7 million loss" - dollar amount
- "outside independent consultant" - unnamed, doesn't count

Two QV-eligible facts: specific date + dollar amount → Quantified-Verifiable

fact: $0.7 million loss


reasoning: The paragraph's primary subject is the Board of Directors and its committee structure for cybersecurity oversight. The 'Risk and Information Security Committee' is a named non-generic committee unique to this company, qualifying as a firm-specific fact, but there are no additional hard verifiable facts to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board recognizes importance of info security, full Board has ultimate responsibility, Risk and Information Security Committee is charged with overseeing cybersecurity risks.

Category: Board Governance - the Board and a board committee are the grammatical subjects performing oversight.

Specificity: "Risk and Information Security Committee" - this is a named non-generic committee (not just "Audit Committee"). That's a firm-specific fact. Any other specific facts? No specific dates, numbers, named firms, tools, etc.

So I'm categorizing this as one information security fact that's firm-specific.

fact: Risk and Information Security Committee


reasoning: The paragraph opens with the Board overseeing cybersecurity risk and the Audit Committee receiving briefings, establishing a board governance frame. The subsequent management sentences (CEO/CFO implementing the program, management reviewing assessments) describe the operational layer beneath board oversight rather than the persons' qualifications, making this Board Governance rather than Management Role. CEO and CFO are generic C-suite titles (NOT list), Audit Committee is standard, and 'regular briefings' is a generic cadence — no IS-list facts remain, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Board oversees cybersecurity risk, Audit Committee receives briefings, CEO and CFO implement the program, management reviews assessments.

Category: This is a mixed paragraph. The first two sentences are about Board/Audit Committee oversight. The next sentences are about CEO/CFO and management. The board is the subject initially, then management. The dominant topic seems split between Board Governance and Management Role.

Looking at the subjects: "Our Board oversees" (board), "The Audit Committee receives" (board), "Our CEO and CFO are responsible" (management), "Management reviews" (management).

The paragraph opens with board governance framing but then pivots to describing what management actually does—implementing programs, reviewing assessments, allocating resources. The CEO and CFO function more as operational roles here rather than individual credentials. Given the roughly even split, the opening sentences establish the governance frame, but the substantive content focuses on management execution.

I'm leaning toward Board Governance because the paragraph's core purpose is explaining the oversight structure itself, with the board at the top and management as the implementing layer beneath it. None of the entities mentioned—board, Audit Committee, CEO, CFO—qualify as specific facts anyway.

Looking at the next part, "regular briefings" is just generic cadence language, and there are no named frameworks or concrete details from the IS list, so this section reads as Generic Boilerplate.


reasoning: The paragraph is a comprehensive enumeration of the company's internal cybersecurity measures, processes, and policies — squarely Risk Management Process. The CISO mention at the very end is incidental attribution within a long process list, not about the person's qualifications or background. The CISO title is a cybersecurity-specific role (one IS-list fact → Firm-Specific), but all other items (incident response plan, penetration testing, vulnerability management, etc.) are generic practices on the NOT list, and no named frameworks, tools, firms, dates, or quantities appear, so it does not reach Quantified-Verifiable.

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

Content: This is a long list of security measures, processes, and policies the company implements. It's describing internal cybersecurity processes and tools.

Category: Risk Management Process - This is clearly about the company's own internal processes, tools, and methodologies. The CISO mention at the end is incidental attribution, not about the person.

Specificity: Let me check the facts:
- "CISO" - this is a cybersecurity-specific title → IS list item → Firm-Specific
- Everything else is generic practices: incident response plan, vulnerability management, penetration testing, etc.

Looking at the rest of the content, I see generic references like cybersecurity insurance and security standards without specific names or certifications mentioned. So I've got one IS fact with the CISO title, but no quantifiable facts like dates, amounts, headcounts, or named tools. This lands it as Firm-Specific (3).

fact: dedicated CISO


reasoning: The paragraph describes CIM Group's cybersecurity risk management policies, procedures, and controls on behalf of the company — including security assessments, penetration testing, vulnerability management, and NIST CSF alignment. This is squarely about internal cybersecurity processes. While CIM Group is a named affiliated management entity, it functions as the company's own IT infrastructure (not a vendor being overseen), so this is Risk Management Process, not Third-Party Risk. The NIST CSF reference triggers Sector-Adapted, but the remaining content (pen testing, vulnerability management, employee training, audits) consists of common practices on the NOT list, and CIM Group is effectively a company self-reference/affiliate rather than an independent third-party firm on the IS list.

thinking:
Let me analyze this paragraph.

Content: Describes CIM Group's cybersecurity risk management approach including policies, procedures, controls, and framework alignment. The company relies on CIM Group for IT.

Category: This is about the company's cybersecurity processes - risk assessment, framework adoption, vulnerability management, monitoring, etc. Even though CIM Group is a separate entity providing these services, the paragraph describes the risk management processes used. The central topic is the internal cybersecurity program/processes, not vendor oversight. → Risk Management Process

Specificity:
- NIST CSF is named → Sector-Adapted at minimum

- CIM Group appears to be an affiliated entity rather than a third-party vendor, so it doesn't qualify as a named firm for specificity purposes
- The practices mentioned like pen testing and vulnerability management are standard industry practices that don't add specificity
- NIST CSF remains the key named standard → Sector-Adapted classification


reasoning: The paragraph describes the company's internal cybersecurity risk management approach: ERM integration, framework adoption (NIST, ISO), and program goals. The Board is mentioned briefly as context for ERM oversight, but the dominant content is about processes and methodology. Named frameworks (NIST, ISO) elevate beyond Generic Boilerplate, but no firm-specific facts (no cybersecurity-specific roles, dates, tools, or numbers) are present, so it remains Sector-Adapted.

thinking:
Classify this paragraph.

Content: Describes the company's cybersecurity program - ERM integration, frameworks (NIST, ISO), cross-functional approach, goals. The Board is mentioned but only as context for ERM oversight. The primary content is about the company's risk management processes and approach.

Category: Risk Management Process - describes internal processes, framework adoption, ERM integration.

Specificity: Names NIST and ISO frameworks → Sector-Adapted at minimum. Any firm-specific facts? "ERM" is generic. "cross-functional, multilayered approach" is generic. No cybersecurity-specific roles, no specific dates, no named tools.

The mention of established frameworks like NIST and ISO is pushing this toward Sector-Adapted classification.

fact: NIST framework

fact: International Organization for Standardization (ISO)


reasoning: The paragraph describes the MAT's function — when it convenes, what it assesses, how it determines materiality, and to whom it reports. Applying the person-vs-function test: the content is about the process and responsibilities of the team, not about any individual's credentials or background. The CIO and CISO are mentioned as triggers for convening, not as primary subjects. Multiple firm-specific facts (MAT as a named program, CISO, CIO, Risk Committee) but no QV-eligible hard facts (named roles, committees, and internal programs don't count toward QV).

thinking:
Let me analyze this paragraph.

Content: Describes the MAT (Materiality Assessment Team) - its role in assessing/overseeing cybersecurity threats, when it convenes, its responsibilities including materiality determination and reporting to Risk Committee. The CIO and CISO are mentioned as triggers.

Category: This is about an internal management process/team for assessing materiality of cyber incidents. The MAT is a management-level team. It describes what the MAT does (assesses, oversees, determines materiality, communicates to Risk Committee). This is about the function/process, not about specific people. The person-vs-function test: remove the role titles and the paragraph still describes a process.

I'm working through whether this is a management role or a risk management process. The codebook mentions management committees responsible for cybersecurity, but the paragraph focuses on what the MAT does—its responsibilities and decision-making processes—rather than who sits on it. The function-based description suggests this leans toward Risk Management Process.

Looking at the specificity markers: the MAT is a named internal program, and the CIO and CISO are mentioned as triggers for convening rather than as the subject. The Risk Committee is also a named entity. These are all firm-specific facts, but none of them qualify as hard verifiable facts—named roles and internal programs don't meet that threshold. So this is Firm-Specific without any QV-eligible content.

fact: MAT (Materiality Assessment Team) — named internal program with unique identifier

fact: CIO

fact: CISO

fact: Risk Committee


reasoning: The paragraph's communicative purpose is to describe how cybersecurity information reaches the Board — the board being kept informed on 'significant cybersecurity matters' is the governance disclosure. While the COO and CFO are grammatical subjects of the reporting action, they serve as the conduit for board-level oversight, not as cybersecurity-specific leadership whose credentials or background are being described. COO and CFO are both generic C-suite titles (NOT list), 'information technology providers' are unnamed, and no frameworks, dates, or firm-specific facts appear — yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph describes how IT providers inform the COO and CFO, who then update the Board. The primary flow is about information reaching the Board - but let me look more carefully.

The grammatical subjects: "IT providers" inform COO/CFO, then "COO and CFO" update the Board. The paragraph describes a reporting chain from providers → management → board.

The dominant purpose is describing how cybersecurity information flows up to the board. The board is the ultimate recipient. But the active subjects are the COO/CFO updating the board. This is a bit of a mix.

Per Rule 2: "Management role reports TO the board → Management Role" and "CISO reports quarterly to the Board on..." → Management Role (management is primary actor).

I'm reconsidering whether the COO and CFO here represent the persons or the function they perform. The paragraph is describing a reporting structure and information flow rather than individual credentials, which points toward Management Role. When the grammatical subject is management performing the action of reporting to the board, that fits the Management Role category, even though COO and CFO are generic C-suite titles. The COO and CFO are the primary actors reporting to the board, which points toward Management Role per the rules, but they're not cybersecurity-specific positions—they're generic C-suite executives. The core tension is whether this is about the reporting structure itself (Management Role) or the board's governance oversight (Board Governance). Given that the paragraph's main point is showing the board stays informed on cybersecurity matters, I'm leaning toward Board Governance as the better fit, since the communicative purpose is demonstrating governance, not describing a cybersecurity leadership role.

Actually, checking the specificity: COO and CFO are both on the NOT list as generic C-suite, the board is generic, and there are no named standards or specific facts from the IS list. This is Generic Boilerplate with Specificity 1.


reasoning: This is a cross-reference to Item 1A Risk Factors with no materiality assessment or substantive cybersecurity disclosure content — just a pointer to another section of the filing.


reasoning: The paragraph is about the people — the CIO and VP of Information Security, their experience (25 years), backgrounds, and team composition. It passes the person-vs-function test: the content centers on who these individuals are and what qualifies them, not on what the program does. Only one QV-eligible fact (25 years), so Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes two management roles (CIO and VP of Information Security) and their qualifications/experience. It's primarily about the people - their experience, background, and team composition.

Content Category: Management Role - The paragraph is about the persons (CIO, VP Information Security), their qualifications, experience, and team. The person-vs-function test: the paragraph tells us about who these people are and their backgrounds.

Specific facts:
- CIO (cybersecurity-specific title per IS list)
- Vice President, Information Security (cybersecurity-specific title)

- Over 25 years of industry experience is a concrete metric that could be verified, but standing alone it doesn't meet the QV threshold. The team composition details—application security, security operations, forensic and incident response, governance, risk and compliance—are firm-specific facts about how the organization structures its security function.

fact: Vice President, Information Security

fact: over 25 years of industry experience

fact: Team areas: application security, security operations, forensic and incident response, governance, risk and compliance


specificity_confidence: medium

reasoning: The board of trustees is the grammatical subject overseeing cybersecurity risk, and the paragraph focuses on board-level expertise, making this Board Governance. Two named board members and a specific headcount ('two') are firm-specific facts; however, named individuals are not on the QV-eligible list (which requires items like dates, dollar amounts, named third-party firms, named tools, or named certifications), so only one QV-eligible fact (headcount) is present, keeping this at Firm-Specific rather than Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

Content: Board of trustees oversees cybersecurity risk. Two board members have security expertise - names Nathaniel A. Davis and Patricia L. Gibson with their cybersecurity backgrounds.

Category: Board Governance - the board is the grammatical subject, discussing board oversight and board member expertise.

Specificity: Named individuals (Nathaniel A. Davis, Patricia L. Gibson) are QV-eligible facts. Two named individuals = two hard verifiable facts → Quantified-Verifiable.

Wait - named individuals. The QV-eligible list says: "specific dates, dollar amounts, headcounts/percentages, named third-party firms, named products/tools, named certifications held by individuals, years of experience, named universities." Named individuals aren't explicitly on the QV list.

But they're company-specific facts that distinguish this organization. The question is whether naming board members with their expertise qualifies as QV-eligible or just firm-specific. Since the QV criteria don't explicitly include named individuals—only named third parties, products, certifications, and institutions—these board members likely fall into firm-specific rather than quantified-verifiable territory.

fact: Two board members have information security expertise

fact: Nathaniel A. Davis — named board member with IT/cybersecurity expertise

fact: Patricia L. Gibson — named board member with cybersecurity expertise


reasoning: The paragraph mentions a specific 2018 incident as an example, but its primary communicative purpose is the materiality assessment ('have not materially affected us, including our business strategy, results of operations or financial condition'). Per the tiebreaker rule, a brief mention of a past incident combined with a materiality conclusion as the main point yields Strategy Integration. Two QV-eligible hard facts are present: the specific date (June 2018) and the dollar amount ($10 million).

thinking:
Let me analyze this paragraph carefully.

This paragraph covers multiple topics:
1. Third-party service providers (brief mention)
2. Past cybersecurity threats experienced
3. A specific incident from June 2018 ($10M fraudulent payments)
4. A materiality assessment
5. A cross-reference to Risk Factors

The dominant purpose: This paragraph describes a past incident AND makes a materiality assessment. Let me apply the tiebreakers:

- "Brief mention of a past incident + materiality conclusion as the main point → Strategy Integration"

Actually, the incident is described with specifics (June 2018, $10M, nature of attack), but the paragraph's overall arc is: we've had threats, here's an example, but they haven't materially affected us.

The materiality conclusion is really what drives this paragraph. Even though the incident details are there—the specific date, the dollar amount, the nature of the attack—they're all in service of the main point: that despite these threats, they haven't had a material impact. So this falls under Strategy Integration, where the incident example supports the broader materiality assessment.

For the QV classification, I've got two solid verifiable facts: the June 2018 date and the $10 million figure, which puts this in Quantified-Verifiable territory.

fact: June 2018 incident date

fact: $10 million in fraudulent electronic payment disbursements


reasoning: While the paragraph describes a specific June 2018 incident, the incident serves as a supporting example for the paragraph's primary communicative purpose: the materiality assessment ('Risks from cybersecurity incidents... have not materially affected us, including our business strategy, results of operations or financial condition'). Per the tiebreaker rule, a brief mention of a past incident plus a materiality conclusion as the main point → Strategy Integration. Two QV-eligible hard facts (specific date June 2018, dollar amount $10M) yield Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

This paragraph covers multiple topics:
1. Third-party service providers (brief mention)
2. Past cybersecurity incidents including a specific June 2018 incident with $10M loss
3. Materiality assessment ("have not materially affected us...")
4. Cross-reference to Risk Factors

The dominant purpose: This paragraph describes a specific incident (June 2018, $10M fraudulent payments, unauthorized email access) AND makes a materiality assessment.

Looking at the tiebreakers:
- "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure"

- But the next thinking suggests the materiality conclusion is actually the main point, with the incident serving as supporting detail.

The structure is really: we use third parties, we've had incidents, here's the June 2018 example, and these haven't materially affected us. So the materiality assessment is the takeaway, not the incident itself.

Since there are two specific facts here—the June 2018 date and the $10 million amount—this qualifies as Quantified-Verifiable.

fact: $10 million in fraudulent payment disbursements