reasoning: The paragraph describes a specific cybersecurity incident including the date, unauthorized access, encryption deployment, scope of affected systems, operational disruptions, and response actions, directly matching Incident Disclosure criteria. It contains one hard verifiable fact (specific date), qualifying as Firm-Specific with no additional verifiable facts for Quantified-Verifiable.


content_category: Incident Disclosure

category_confidence: high

specificity_confidence: high

reasoning: Paragraph describes an actual cybersecurity incident including unauthorized access by a cybercrime organization, exfiltration of limited customer and employee PII from a portion of the retail business information environment, and response actions like investigation with external experts and notifications to affected parties, regulators, and law enforcement. No specific verifiable facts, named entities, dates, or standards qualify it beyond generic boilerplate.

provider: x-ai


content_category: Board Governance

reasoning: The paragraph describes the board of directors' oversight of strategic and operational risks, including cybersecurity, and delegation to the audit committee for reviewing risk management practices, making Board Governance the most applicable category as the board and committee are the grammatical subjects.


reasoning: Paragraph details a specific cybersecurity incident including detection date, unauthorized access, response actions (incident response activation, external experts, law enforcement notification), and operational impacts, matching Incident Disclosure criteria. Contains one verifiable specific date, meeting Firm-Specific threshold without reaching Quantified-Verifiable (needs two hard facts).


content_category: None/Other

reasoning: This paragraph is a cross-reference to the risk factors section with a generic risk factor title, providing no substantive cybersecurity disclosure on governance, processes, incidents, or strategy.


content_category: Strategy Integration

reasoning: The paragraph provides standalone materiality conclusions stating no prior cybersecurity incidents have materially affected the company and that future threats could, with no incident narrative or description of events. It fits Strategy Integration per guidelines for materiality assessments without incident details, and includes a cross-reference but the core is materiality.


content_category: Risk Management Process

reasoning: The paragraph details the company's internal risk management processes, including integration of cybersecurity into enterprise risk reviews on a biannual basis, involvement of CISO and CIO, mitigation plans, and annual Board reviews, making 'Risk Management Process' the best fit as it centers on the company's own processes rather than board oversight or management roles primarily.


reasoning: The paragraph describes a specific cybersecurity incident including detection date, scope (Canadian operations), response actions (isolation, engagement of professionals, recovery efforts), and operational impacts, matching Incident Disclosure criteria. It contains one hard verifiable fact (specific date) qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second such fact.


reasoning: Paragraph describes an actual cyberattack incident on Change Healthcare services, including scope (pharmacy, medical claims, payment services), response actions (mitigating impact, restoring services, investigating with law enforcement), and operational status, fitting Incident Disclosure. Contains one firm-specific named system (Change Healthcare), qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard verifiable fact.


content_category: Management Role

reasoning: The paragraph identifies the Chief Technology Officer (CTO), describes their qualifications and responsibilities for cybersecurity risk management, and reporting to the General Counsel, making Management Role the clear fit as management roles are the grammatical subject.


reasoning: The paragraph outlines the company's internal activities for monitoring emerging data protection laws and implementing process changes to manage cybersecurity risks and ensure compliance, which aligns with Risk Management Process as it focuses on the company's own processes.


reasoning: The paragraph focuses on identifying and describing the qualifications, experience, and responsibilities of specific management roles (CIO and Information Security Director) and their supporting team, which directly matches the 'Management Role' category. No board oversight, processes, incidents, or third-parties are the primary subject.


reasoning: The paragraph assesses the materiality of past cybersecurity incidents (none material, immaterial expenses, no penalties) and future response plans without describing any specific incident events, aligning with Strategy Integration for materiality conclusions. No qualifying specific facts from the ✓ IS list (no dates, roles, firms, numbers, or named entities), confirming Generic Boilerplate.


reasoning: The paragraph describes the Adviser's internal program and controls for assessing, identifying, managing, and escalating cybersecurity threats and incidents, focusing on the company's own processes, which aligns with Risk Management Process. It contains no named frameworks, roles, dates, numbers, or other specific facts from the ✓ IS list, making it Generic Boilerplate.


reasoning: The paragraph centers on the chief financial officer's primary responsibility for assessing, monitoring, and managing cybersecurity risks, including oversight by consultants and updates to the Nomination and Corporate Governance Committee, fitting Management Role as the main focus with board mention being brief.


reasoning: The paragraph describes the Audit Committee's central role in overseeing cybersecurity risks and how it receives regular updates from senior IT leadership, with the board committee as the grammatical subject. No firm-specific facts or named standards are present, confirming generic boilerplate.


reasoning: The paragraph details the ongoing investigation into a cybersecurity incident, current findings on data access (no evidence of customer data taken), response actions (reporting to law enforcement and regulators), and operational/financial impact, directly fitting Incident Disclosure criteria including scope and response for a real event. It does not qualify as Strategy Integration alone since it includes incident-specific response and scope details beyond just materiality.


reasoning: The paragraph focuses on the Board of Directors and Enterprise Risk Management Committee's oversight, training, approvals, and reporting on cybersecurity, with the board/committee as the grammatical subjects, fitting Board Governance. It includes a named non-generic committee as a firm-specific fact but lacks named frameworks or two+ verifiable hard facts.


reasoning: The paragraph details the company's internal cybersecurity program, including the CDRM organization led by the Global CISO, risk identification/assessment/mitigation processes, and use of NIST framework, which centers on the company's own risk management processes. It contains firm-specific elements like the named role and organization, exceeding Sector-Adapted.


reasoning: The paragraph describes the company's internal incident response policies, escalation procedures, and involved teams, which aligns with Risk Management Process as it focuses on IR planning and own internal processes. It contains named internal teams/committees qualifying as firm-specific facts but lacks two or more hard verifiable facts for higher specificity.


reasoning: The paragraph details the company's own internal processes for managing cybersecurity risks, including employee training, awareness updates, employee testing, penetration testing, and cybersecurity assessments, making 'Risk Management Process' the most applicable category. No specific facts from the ✓ IS list are present, and common practices like penetration testing do not qualify, resulting in Generic Boilerplate specificity.


reasoning: The paragraph provides materiality conclusions stating no material impact from cybersecurity risks or past incidents on business or financials, with a brief mention of strategy updates, aligning with Strategy Integration tiebreakers for materiality assessments without incident narratives. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph focuses on Mr. Gharib's specific responsibilities in hiring, risk integration, budgeting, incident preparation, and reviewing assessments, making a management role (cybersecurity leader) the grammatical subject. No other category fits as centrally, with no board, processes, vendors, incidents, or strategy mentioned.


reasoning: This paragraph details the company's own internal processes for risk assessments, threat and vulnerability identification, risk prioritization, and mitigation strategies including incident response plans, fitting the Risk Management Process category. No specific facts, named frameworks, roles, or quantifiable details are present, making it Generic Boilerplate.


reasoning: The paragraph describes the company's own internal cybersecurity program integration into various risk management systems and processes, which fits Risk Management Process; third-party risk is mentioned only as one component, not centrally. No named frameworks, cybersecurity-specific roles, dates, numbers, or other firm-unique facts qualify under the ✓ IS list, resulting in Generic Boilerplate.


reasoning: The paragraph focuses on identifying the CISO and CTO, their qualifications, tenure, and experience, making 'Management Role' the clear fit as these roles are the grammatical subjects. Multiple hard verifiable facts including specific dates (2013, 2020), quantified experience years, and named certifications exceed the threshold for Quantified-Verifiable.


reasoning: The paragraph begins with the AGM board of directors as the grammatical subject overseeing the risk management program, including cybersecurity, which aligns with Board Governance criteria. It mentions integration into ERM and use of NIST and ISO frameworks, but the primary focus is board oversight rather than the company's internal processes alone.


reasoning: The paragraph details the company's internal processes for managing cybersecurity risks through embedding into business processes and collaboration between the enterprise risk management team, CSO, and IT risk management team, fitting Risk Management Process. It includes a cybersecurity-specific role (CSO), qualifying as Firm-Specific.


reasoning: The paragraph addresses the potential materiality of cybersecurity risks, resource expenditures including cyber insurance costs, and states no material past incidents have occurred, aligning with Strategy Integration criteria for business/financial impact and materiality assessments without incident narrative. No specific facts, frameworks, or unique details are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes the company's processes for assessing, identifying, and managing cybersecurity risks, which aligns with Risk Management Process. It contains no specific facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph discusses the company's engagement of external experts for audits, threat assessments, and penetration testing as part of its own cybersecurity risk management processes, fitting Risk Management Process; third parties are a component of internal processes, not the central focus of vendor oversight.


reasoning: Paragraph states no material cybersecurity incidents or expenses in the last three fiscal years with a materiality conclusion and cross-reference, fitting Strategy Integration per tiebreakers for standalone materiality without incident narrative. No qualifying specific facts or named standards, making it Generic Boilerplate.


reasoning: The paragraph focuses on the Board of Directors assigning the Audit Committee responsibility for cybersecurity risk oversight, including annual reviews and incident reporting, which aligns with Board Governance as the board/committee is the grammatical subject. No firm-specific facts qualify under the ✓ IS list, as Audit Committee, Board, annual cadence, and IRP are all generic or on the ✗ NOT list.


reasoning: The paragraph focuses on the Audit Committee and full Board's oversight, briefings, and education on cybersecurity from management and specific officers, making Board Governance the primary category as board/committees are the grammatical subjects. Management roles are mentioned as presenters but not the main focus.


reasoning: Paragraph provides a standalone materiality conclusion that no cybersecurity threats in 2023 materially affected or are likely to affect business strategy, operations, or financial condition, with no incident narrative, aligning with Strategy Integration. Includes one specific date ('In 2023'), qualifying as Firm-Specific but not reaching Quantified-Verifiable threshold.


reasoning: This paragraph details the company's incident response plan, including processes for triage, investigation, containment, and remediation, which describes their own internal risk management processes focused on IR planning. It mentions third-party providers only as a component of the internal plan, not as the central topic.


reasoning: The paragraph details the company's internal cybersecurity risk management program, including committee meetings, employee training, and security policies, which aligns with Risk Management Process as the company's own processes are the central topic. Vendor management is mentioned only as an example within policies, not as the central focus.


reasoning: The paragraph focuses on the CISO and CTO roles, their reporting lines (CISO reports to CTO), responsibilities, and leadership in cybersecurity, making management roles the grammatical subject and central topic. Third-party consultants and penetration testing are mentioned as part of CISO oversight, not as central vendor risk management.


reasoning: The paragraph describes the company's internal cross-functional processes for risk identification, strategy development, threat mitigation, and incident response escalation, which aligns with Risk Management Process. It briefly mentions management and Board involvement but focuses on overall internal processes rather than board oversight or management roles.


reasoning: The paragraph describes the company's internal processes for assessing control effectiveness through third-party ethical hacks, penetration tests, and program reviews, which aligns with Risk Management Process. Third-party engagement is a component of these internal processes, not the central focus on vendor oversight.


reasoning: The paragraph focuses on identifying and detailing qualifications of specific management roles (Vice President of Information Systems and CFO) involved in cyber risk management, making 'Management Role' the best fit. It contains multiple hard verifiable facts including specific years of tenure/experience and named certification body (GIAC), exceeding the threshold for Quantified-Verifiable.


reasoning: The paragraph focuses on the Board establishing a Cybersecurity Committee for oversight of cybersecurity risks and details the chair's expertise, making the board/committee the grammatical subject, which aligns with Board Governance. It contains multiple hard verifiable facts including a specific date (2023), named committee, and named third-party entities (NACD, CERT, Carnegie Mellon), exceeding the threshold for Quantified-Verifiable.


reasoning: This paragraph is a cross-reference to the Risk Factors section, providing no substantive cybersecurity disclosure, which fits 'None/Other' per guidelines.


reasoning: This paragraph details the company's internal audit program, which conducts annual business risk assessments including cybersecurity risks and reports to business team leaders, fitting the Risk Management Process category as it focuses on the company's own internal risk assessment processes.


reasoning: The paragraph details the company's engagements with third-party firms to enhance its own internal processes like crisis simulations, monitoring, incident response, and threat intelligence, making Risk Management Process the best fit as vendors are components of internal processes rather than the central oversight topic.


reasoning: Paragraph discusses general cybersecurity threats, risks to the company and third parties, and the need to expend resources in boilerplate fashion with no substantive disclosure on governance, processes, incidents, or strategy.


reasoning: Paragraph provides a standalone materiality assessment concluding no material impact from past cybersecurity incidents or threats during the fiscal year, with forward-looking risks; matches Strategy Integration for materiality conclusions without incident narrative.


content_category: Third-Party Risk

reasoning: The paragraph centrally focuses on assessing, selecting, overseeing, and managing risks from third-party vendors, suppliers, and service providers, which matches Third-Party Risk; it is not merely a component of broader internal processes. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph discusses potential material adverse effects of hypothetical cybersecurity incidents and mentions cybersecurity insurance coverage without describing any specific event or process, aligning with Strategy Integration for financial impact and insurance. It includes forward-looking disclaimers and a cross-reference, but the core content fits materiality assessments and cyber insurance.


reasoning: The paragraph discusses the company's internal risk management processes that incorporate assessment of cybersecurity threats from third-party service providers, including due diligence in selection and oversight, treating third-party risks as a component of overall internal processes per tiebreakers.


reasoning: The paragraph describes the Board of Directors and Audit Committee's oversight of cybersecurity risks, including update cadences, making the board/committee the grammatical subjects and fitting Board Governance. No firm-specific facts or named standards are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph focuses on the Board and audit committee's oversight of cybersecurity risks, including delegation of responsibilities and quarterly reporting cadence, with the board/committee as the grammatical subjects. No firm-specific facts qualify under the ✓ IS list, as all elements (Board, audit committee, management, quarterly reports) are on the ✗ NOT list.


reasoning: The paragraph centers on identifying Jack Wang and his qualifications, responsibilities, and reporting lines for cybersecurity, which aligns with Management Role as the grammatical subject is this management figure rather than the board or internal processes.


reasoning: The paragraph describes the company's own internal processes for monitoring, vulnerability remediation, incident response exercises, penetration testing, and employee training, making Risk Management Process the best fit. It contains no named frameworks, cybersecurity-specific roles, dates, named programs with unique identifiers, or other specific facts from the ✓ IS list, resulting in Generic Boilerplate.


reasoning: The paragraph focuses on the Board's responsibility for oversight of cybersecurity risks, delegation to the Audit Committee, and the committee's reviews and expertise, fitting the Board Governance category as the board and committee are the grammatical subjects.


reasoning: The paragraph describes the company's internal cybersecurity risk management program integrated into its Enterprise Risk Management process, focusing on identifying, managing, and assessing risks, which aligns with Risk Management Process. No specific facts, named standards, or unique details are present, making it generic boilerplate.


reasoning: The paragraph describes the company's adoption of cybersecurity risk management processes using a risk-based approach to assessing, identifying, and managing risks, integrated into overall risk management, which fits Risk Management Process. Board oversight is mentioned briefly as introductory context, not the central focus.


reasoning: The paragraph details the company's own internal processes and measures for managing cybersecurity risks, such as incident response plans, risk assessments, encryption, monitoring, and employee training, which aligns with Risk Management Process. It contains no named frameworks, specific roles, dates, programs, tools, firms, or quantifiable details, making it Generic Boilerplate.


category_confidence: medium

reasoning: The paragraph identifies the Vice President of Operations as directing cybersecurity programs and monitoring incidents, fitting Management Role for role identification and reporting lines; board oversight is mentioned but the specific management role is central.


reasoning: The paragraph details the company's internal vulnerability assessment program, enterprise-wide framework for cybersecurity risk management, and ongoing vulnerability evaluation processes, which directly align with Risk Management Process as it focuses on the company's own risk assessment and vulnerability management practices.


reasoning: This paragraph details the company's internal processes for incident detection, severity assessment via a matrix, notification, escalation, and triage through its Security Operations Center, which aligns with Risk Management Process as it focuses on the company's own cybersecurity monitoring and IR planning without referencing boards, management roles, vendors, or actual incidents.


reasoning: The paragraph discusses the company's implementation of the NIST Cybersecurity Framework and adoption of internal policies to align with regulatory requirements, which directly pertains to its own risk management processes including framework adoption.


reasoning: The paragraph describes the company's internal processes for monitoring, assessing, and escalating cybersecurity incidents via its information security team and incident response plan, which fits Risk Management Process. Brief mentions of escalation to management, Committee, and Board do not shift the primary focus.


reasoning: The paragraph describes the company's own internal processes and measures for managing cybersecurity risks, such as vulnerability management, incident response, monitoring, and vendor risk processes as one component, aligning with Risk Management Process rather than Third-Party Risk where vendors would be central. It lacks any named frameworks, specific roles, dates, numbers, or unique facts, qualifying as Generic Boilerplate.


reasoning: The paragraph focuses on the Director of Cybersecurity's responsibilities, qualifications, and reporting lines to the Head of IT and executive committee, making 'Management Role' the clear fit as management roles are the grammatical subjects. It contains cybersecurity-specific roles and a quantified experience metric, qualifying as Firm-Specific with no hard verifiable facts reaching Quantified-Verifiable threshold.


reasoning: The paragraph describes the IT department's involvement in assessing, managing, monitoring, and reporting on cybersecurity risks as part of the company's internal risk management process, making Risk Management Process the best fit; Audit Committee reporting is brief and does not shift focus to Board Governance, and no cyber-specific roles like CISO are identified.


reasoning: The paragraph describes the company's internal processes for overseeing cybersecurity risks associated with third-party service providers and includes materiality assessments with no incident details, fitting Risk Management Process as vendors are a component rather than the central topic; tiebreakers prioritize internal processes over standalone materiality or third-party focus.


reasoning: The paragraph describes a specific cybersecurity incident including the date it was detected, unauthorized access by a threat actor, data encryption, and immediate response actions such as containment, internal investigation, engaging specialists, and restricting access, fitting Incident Disclosure. It contains one hard verifiable fact (specific date), qualifying as Firm-Specific but not Quantified-Verifiable.


reasoning: Paragraph discusses materiality and business impact of an incident without describing the event itself (no dates, access details, or response actions), fitting Strategy Integration per tiebreakers for financial/materiality assessments. No specific facts, named standards, or verifiable details present, making it generic boilerplate.


reasoning: This paragraph details a specific cybersecurity incident including the detection date, unauthorized access to IT systems, and response actions like investigation, incident response plan activation, system shutdown, and law enforcement notification, directly matching Incident Disclosure criteria. It includes one verifiable specific date, meeting Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: The paragraph details the detection of unauthorized activity, containment and remediation steps including a specific date of system isolation, retention of experts, and notifications to law enforcement and regulators, directly describing a real cybersecurity incident and response actions.


reasoning: The paragraph details the company's own internal processes for managing cybersecurity risks, including purchasing cyber insurance, maintaining business continuity/disaster recovery plans, and testing incident response readiness via annual tabletop exercises. No board oversight, specific management cyber roles, incidents, or third-party focus is present.


reasoning: The paragraph focuses on the materiality assessment of the incident's impact on operations and financial condition without describing the event itself, aligning with Strategy Integration per tiebreakers for financial/materiality discussions lacking incident narrative. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes investigation findings and ongoing response to a specific cybersecurity incident, including lack of evidence for malware or ongoing access and assessment of scope/impact, fitting Incident Disclosure. No specific dates, names, numbers, or other firm-unique facts are present, making it Generic Boilerplate.


reasoning: The paragraph describes the details of a cybersecurity incident, including unauthorized access and exfiltration of limited data (including some PII) by a threat actor, and ongoing response actions like notifications, referencing a real event tied to the 'Original Report'. No firm-specific or verifiable facts are present, as terms like 'limited data' and 'some personally identifiable information' are vague and generic.


reasoning: This paragraph details response actions (contain and remediate the incident), scope of non-compromised systems (Bank’s own IT systems and networks unaffected), absence of unauthorized transactions or fund transfers, and operational continuity for members, directly matching Incident Disclosure criteria for describing a real incident's response, scope, and impact.


reasoning: Paragraph describes a specific past cybersecurity incident including dates (May/June 2023), unauthorized access and exfiltration of SharePoint files, investigation, and response actions, fitting Incident Disclosure. Contains multiple hard verifiable facts (two specific dates and named system), exceeding the threshold for Quantified-Verifiable.


reasoning: This paragraph details the operational impacts, scope of affected products/services, recovery status, and revenue percentage tied to a specific incident, fitting Incident Disclosure as it describes the event's effects and response without focusing on financial materiality alone.


reasoning: Paragraph details the detection date, initiation of response protocols, investigation, engagement of a firm, notifications, and containment of a specific cybersecurity incident, directly matching Incident Disclosure criteria with narrative of what happened and response actions. It includes one hard verifiable fact (specific date), meeting Firm-Specific but not Quantified-Verifiable threshold.


reasoning: The paragraph describes a specific cybersecurity incident including unauthorized activity detection, containment steps, and a precise date for system isolation, matching Incident Disclosure criteria. It contains one verifiable specific date, qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: Paragraph details a specific cybersecurity incident including the date it was detected, unauthorized access by a threat actor, data encryption, and immediate response actions like containment and engaging specialists, directly matching Incident Disclosure criteria. It includes one verifiable specific date, qualifying as Firm-Specific with no additional hard facts for Quantified-Verifiable.


reasoning: This paragraph is a standard forward-looking statement disclaimer, which falls under None/Other as it contains no substantive cybersecurity disclosure.


reasoning: The paragraph focuses on the materiality conclusion and specific financial impacts (EPS figures) of the Incident on Q2 results without describing the event itself, aligning with Strategy Integration per tiebreakers. It contains multiple hard verifiable facts (specific quarter-end date and dollar amounts), exceeding the threshold for Quantified-Verifiable.


reasoning: This paragraph assesses the materiality of a cybersecurity incident on business operations and financial condition without any incident narrative or description of events, aligning with Strategy Integration per tiebreakers for financial/materiality discussions absent event details.


reasoning: This paragraph details the operational impacts (shipping, receiving, manufacturing, support functions), evidence of files taken, and response actions (interim measures, investigation, review, notifications) of a specific cybersecurity incident, directly matching Incident Disclosure criteria including scope and response without focusing on financials or materiality.


reasoning: The paragraph assesses the materiality of an ongoing cybersecurity incident on operations and financial condition without describing the event itself, matching the tiebreaker for Strategy Integration. No specific facts, frameworks, or details are present, making it generic boilerplate.


reasoning: Paragraph discusses financial costs (material expenses in first quarter), cyber insurance, and materiality of an incident without describing the event itself, fitting Strategy Integration per tiebreakers. No incident narrative or response details beyond generic notifications.


reasoning: Paragraph describes the scope of a real cybersecurity incident, specifying the number of affected consumers and data types not stolen, which matches Incident Disclosure criteria including affected data scope.


reasoning: The paragraph discusses financial expenses, materiality assessment of the incident's impact on financial condition and operations, and ongoing business risks without describing the incident itself or any response actions, fitting Strategy Integration per tiebreakers. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes the scope of data exfiltrated in a cybersecurity incident, specifying the types of information affected and tying it to preparations for a specific fiscal year's 10-K filing, which fits Incident Disclosure as it details affected data scope for a real event.


reasoning: This paragraph describes the scope of a cybersecurity incident, including details on exfiltrated data (PII and PHI from a subsidiary providing patient support services), aligning with Incident Disclosure criteria for affected data/systems. No qualifying specific facts from the ✓ IS list (no dates, named roles, firms, tools, or quantifiable metrics) or named standards, confirming Generic Boilerplate specificity.


reasoning: Paragraph details a real cybersecurity incident with date, ransomware nature, affected systems, and response actions including containment and expert engagement, directly matching Incident Disclosure criteria. Includes one verifiable specific date, qualifying as Firm-Specific with no additional hard facts for Quantified-Verifiable.


reasoning: The paragraph focuses on financial impacts (expenses and lost revenue) from a cybersecurity incident without describing the event itself, fitting Strategy Integration per tiebreakers. It contains multiple hard verifiable facts including specific fiscal periods and dollar amounts, qualifying for Quantified-Verifiable.


reasoning: Paragraph focuses on financial and operational materiality assessments and risks from 'this incident' without describing the event, scope, or response actions, matching Strategy Integration per tiebreakers. Contains two specific date periods (quarter ended December 31, 2024 and full year 2024), qualifying as Quantified-Verifiable.


reasoning: This paragraph describes response actions to a specific cybersecurity incident, including launching an investigation, notifying law enforcement, regulators, and users about unauthorized access to personal information, fitting the Incident Disclosure category. No specific facts like dates, named firms, or quantifiable details are present, making it Generic Boilerplate.


reasoning: This paragraph provides a narrative of a specific cybersecurity incident, detailing unauthorized access to the company's environment and files, a misdirected $250,000 wire payment, deletion of email messages, and non-recovery of the payment, directly matching Incident Disclosure criteria. It includes one verifiable quantified fact ($250,000), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact like a date or named firm.


reasoning: Paragraph details response actions to a cybersecurity incident (system restoration, expert retention, law enforcement coordination, notifications) and specifies the scope (limited to Change Healthcare systems, others operational), directly matching Incident Disclosure criteria.


reasoning: This paragraph focuses on the materiality assessment of an incident's impact on business operations and financial condition, with no description of the event itself, aligning with Strategy Integration per tiebreakers. It references the incident's limitation to Dropbox Sign infrastructure but emphasizes ongoing risks and remediation without incident narrative.


reasoning: The paragraph discusses financial expenses, operational impact, and materiality assessment of 'the Incident' without describing the event itself, fitting Strategy Integration per tiebreakers for financial/materiality focus without incident narrative. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: Paragraph details a specific cybersecurity incident including detection date, access method, exfiltration period, and scope of affected data with precise dates and response actions, fitting Incident Disclosure. Multiple specific dates provide two or more hard verifiable facts, qualifying as Quantified-Verifiable.


reasoning: The paragraph details regulatory determinations on disclosure delays, law enforcement collaboration, suspect apprehension, and data availability status for a specific cybersecurity incident, aligning with Incident Disclosure as it covers response actions and affected data scope without narrating the core event but referencing real incident elements.


reasoning: The paragraph describes a specific cybersecurity incident including the date of identification, how it was detected (employee communications from threat actor), unauthorized access details, and initial response actions, fitting Incident Disclosure per guidelines. It contains one verifiable fact (specific date) making it Firm-Specific but not Quantified-Verifiable due to lacking a second hard fact.


reasoning: This paragraph details the detection of unauthorized activity, specific response actions including system isolation on a precise date, engagement with experts and authorities, and incident containment, directly matching 'Incident Disclosure' criteria for describing a real event's narrative and response.


reasoning: The paragraph describes the ongoing investigation into an actual cybersecurity incident, including details on exfiltrated files, potential sensitive or personal information, and response actions like evaluating notifications, fitting the Incident Disclosure category. No specific facts from the ✓ IS list are present, such as dates, named roles, or quantified elements, resulting in Generic Boilerplate specificity.


reasoning: This paragraph provides a detailed narrative of a real cybersecurity incident, including the specific date of occurrence, unauthorized access by a threat actor, response actions (activating response plan with external experts, containment, remediation, restoration), scope (limited portion of environment), and operational impact (restored within days/hours, no material impact), directly matching Incident Disclosure criteria over Strategy Integration due to the descriptive event details.


reasoning: This paragraph is a standard forward-looking statement disclaimer with no reference to cybersecurity or any substantive disclosure, directly matching the 'None/Other' category description for forward-looking disclaimers and non-cybersecurity content.


reasoning: Paragraph details a real cybersecurity incident with date, unauthorized access to data/systems, and response actions (protocols, investigation, law enforcement notification), matching Incident Disclosure. Includes one verifiable specific date, making it Firm-Specific but not Quantified-Verifiable (only one hard fact).


reasoning: This paragraph details the detection of suspicious activity on a specific date involving IT systems and initial response actions like isolation and investigation, directly matching Incident Disclosure criteria for describing a real event's timeline, scope, and response.


reasoning: Paragraph discusses the potential materiality and financial impact of an incident without any description of the event, scope, or response, aligning with Strategy Integration per tiebreakers for materiality conclusions. Contains one verifiable specific date (March 31, 2026), qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard fact.


reasoning: This paragraph details a real cybersecurity incident with a specific date, description of data exfiltration (including potential personal information), and initial response actions like containment and investigation, directly matching Incident Disclosure criteria.


reasoning: This paragraph focuses on financial expenses, lost production impact, and materiality assessment related to 'the cybersecurity incident' without any narrative description of the event itself, aligning with Strategy Integration per tiebreakers for financial/materiality discussions lacking incident details.


reasoning: The paragraph discusses the lack of material impact from a cybersecurity incident on financial systems, operations, and condition, with ongoing investigation but no incident narrative, aligning with Strategy Integration per tiebreakers for materiality conclusions without event description.


reasoning: This paragraph details a real cybersecurity incident with specific dates, detection details, scope (portion of IT systems), and response actions (investigation, incident response plan activation, system shutdown), fitting Incident Disclosure perfectly. It has specific dates as firm-specific facts but only one unique verifiable date (repeated for two events), not reaching two distinct hard facts for Quantified-Verifiable.


reasoning: The paragraph details specific response actions taken to an actual cybersecurity incident, including containment measures, enhanced monitoring, access reviews, engagement of experts, and notifications, fitting the Incident Disclosure category which includes incident response actions for a real event. No firm-specific facts, named standards, or verifiable details are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph provides an update on the real Change Healthcare cyberattack, including response actions like data assessment, notifications, and service restoration progress, fitting Incident Disclosure as it references a specific event and describes ongoing response. It contains a specific date and named system (Change Healthcare), meeting the threshold for Quantified-Verifiable.


reasoning: The paragraph provides a standalone materiality conclusion regarding a cybersecurity incident's impact on financial condition without any description of the event itself, aligning with Strategy Integration per tiebreakers. No specific facts, dates, roles, or standards are mentioned, confirming Generic Boilerplate specificity.


reasoning: The paragraph provides a detailed narrative of a real cybersecurity incident, including specific dates, ransomware encryption, escalation, and unauthorized data disclosure, fitting Incident Disclosure. Materiality assessments are secondary to the event description.


reasoning: This paragraph describes the company's response actions to a specific cybersecurity incident, including activating the response plan, internal investigation with external advisors, taking systems offline, notifying law enforcement, and ongoing restoration and data assessment, directly matching Incident Disclosure criteria.


reasoning: Paragraph details the scope of an actual cybersecurity incident, including what data was accessed (names, phone numbers, car registration numbers, addresses, emails) and what was not (financial info, passwords), directly matching Incident Disclosure criteria with reference to a real event. Contains one qualifying specific fact (quantified user count), qualifying as Firm-Specific but not Quantified-Verifiable due to only one hard verifiable fact.


reasoning: The paragraph describes ongoing response actions to a specific cybersecurity incident (communication with stakeholders, following internal standards, identifying effects) and operational impact (continued global product/service provision), fitting Incident Disclosure criteria. It references 'the incident' with response details but no event narrative, distinguishing it from Strategy Integration.


reasoning: The paragraph details the subsidiary's response to a specific cybersecurity incident, including activation of protocols, containment measures, investigation with third-party assistance, notification to law enforcement in Singapore, and ongoing restoration and notification efforts, fitting the Incident Disclosure category as it describes response actions to a real event without financial or materiality details.


reasoning: This paragraph contains a standard legal disclaimer about the non-filed status of Item 7.01 under securities laws, with no reference to cybersecurity or substantive disclosure, fitting None/Other.


reasoning: This paragraph details the scope of affected data and what was not compromised in a specific cybersecurity incident, fitting the Incident Disclosure category as it describes the incident's impact on data types without narrative of events or response actions. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph details a specific cybersecurity incident including the detection date, nature of the breach (data exfiltration from information systems, possibly including personal information), and initial response actions (containment and investigation), directly matching Incident Disclosure criteria. It includes one verifiable specific date but no additional hard facts like named firms or products, resulting in Firm-Specific specificity.


reasoning: The paragraph focuses on the materiality assessment of the cyber incident's impact on business operations and financial condition without describing the incident itself, aligning with Strategy Integration per tiebreakers for materiality conclusions. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph details the incident's scope (exfiltrated files, accessed systems, potential sensitive/personal information) and response actions (investigating extent, evaluating notifications), directly describing aspects of a real cybersecurity event per guidelines. No qualifying specific facts, named standards, or verifiable details are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes response actions (containment, ongoing remediation, working with experts) to a specific cybersecurity incident, fitting Incident Disclosure as it references incident response without detailing the event itself or financial impacts. No specific facts from the ✓ IS list or named standards are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph details the company's remediation actions, removal of the intruder, restoration of access, and verification of data integrity following a cybersecurity incident, which aligns with Incident Disclosure as it describes response actions for a real event. No specific facts, dates, names, or quantifiable details are present, making it Generic Boilerplate.


reasoning: The paragraph focuses solely on the financial and operational materiality assessment of a cybersecurity incident without describing the event itself, aligning with Strategy Integration per tiebreakers for materiality conclusions lacking incident narrative.


reasoning: This paragraph is a forward-looking disclaimer about potential cybersecurity incidents and a cross-reference to Risk Factors, containing no substantive disclosure on governance, processes, incidents, or strategy, thus fitting 'None/Other'.


reasoning: Paragraph describes incorporation of cybersecurity risk management into overall enterprise risk management programs, sharing methodologies, reporting, and governance, fitting Risk Management Process via ERM integration. No specific facts, named frameworks, roles, dates, or unique details qualify it beyond Generic Boilerplate.


reasoning: The paragraph focuses on the board of directors' oversight of cybersecurity risks and its receipt of annual updates from the audit committee and executive leadership team, with the board as the grammatical subject. No specific facts qualify under the ✓ IS list, as all elements (board, audit committee, annual cadence, executive team) are generic per the ✗ NOT list.


reasoning: The paragraph describes the company's own internal cybersecurity risk management process, including a risk-based approach to evaluating third-party vendors as one component, which aligns with Risk Management Process per tiebreakers rather than making vendor oversight the central topic.


reasoning: The paragraph focuses on the board of directors and its audit committee overseeing cybersecurity risk management and assessments, directly matching Board Governance criteria where board or committee is the grammatical subject.


reasoning: The paragraph focuses on 'The Committee' (a board committee) receiving reports on cybersecurity risks, updates on incidents, and reporting to the Board, making board/committee oversight the central topic per category guidelines. No specific facts qualify under the ✓ IS list, as 'The Committee' and 'periodic' reports are generic per the ✗ NOT list.


reasoning: The paragraph describes the general professional experience of Mr. Tao in business consultation, operations, management, and marketing, with no mention of cybersecurity, roles, processes, or incidents, making it non-cybersecurity content under None/Other.


reasoning: This paragraph discusses the company's investments in cybersecurity resiliency and enhancements to internal controls and processes to protect systems and data, which directly pertains to the company's own internal risk management practices.


reasoning: The paragraph details the company's own cyber risk management program for identifying, assessing, managing, mitigating, and responding to threats, integrated with enterprise risk management, fitting Risk Management Process. No specific facts, frameworks, roles, or details are present, making it Generic Boilerplate.


reasoning: The paragraph discusses the company's implementation of a cybersecurity program within its enterprise risk management process to assess, identify, and manage cybersecurity risks, directly aligning with Risk Management Process as it focuses on internal processes without referencing board, management roles, incidents, or third parties.


reasoning: The paragraph provides a generic statement on operational dependence on software, networks, and third-party systems without referencing any cybersecurity-specific processes, governance, incidents, or strategies, making it non-substantive disclosure.


reasoning: The paragraph describes the purpose of the company's cybersecurity program, which aligns with its own internal risk management processes. It contains no specific details, incidents, governance, or third-party focus.


reasoning: The paragraph focuses on the identification and qualifications of a specific cybersecurity management role, including experience and join date, making 'Management Role' the most applicable category.


reasoning: Paragraph discusses financial and operational materiality of an incident without describing the event, scope, or response, aligning with Strategy Integration per tiebreakers for materiality conclusions. No qualifying specific facts from the ✓ IS list (no cybersecurity roles, dates, named firms, quantified metrics, or unique programs); references to 'Targus' and 'Operating Adjusted EBITDA' are company self-references or non-cybersecurity specifics excluded by ✗ NOT list.


reasoning: The paragraph outlines oversight of cybersecurity policies, procedures, compliance, and evaluation of the Cybersecurity Committee's composition and performance, making board or committee oversight the central topic fitting Board Governance. It contains a named non-generic committee as a firm-specific fact but lacks two or more hard verifiable facts for higher specificity.


reasoning: The paragraph identifies management roles ('head of the ITS Department' and 'executive management') as primarily responsible for assessing and managing cybersecurity risks, making 'Management Role' the most applicable category. No board oversight or internal processes are described, and 'head of the ITS Department' does not qualify as a cybersecurity-specific title per the guidelines (not CISO/CTO/CIO or equivalent), resulting in no specific facts and generic boilerplate specificity.


reasoning: The paragraph describes the integration of cybersecurity risk management into the company's overall enterprise risk management program, which fits Risk Management Process as it focuses on the company's own internal processes and ERM integration. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph focuses on the audit committee reporting to the board and the board receiving briefings from management on cybersecurity risks, with the board and committee as the grammatical subjects, fitting Board Governance. No firm-specific facts or named standards are present, confirming Generic Boilerplate.


reasoning: The paragraph details the company's internal policies and employee training programs for protecting PII, which falls under own internal risk management processes. It contains no named frameworks, cybersecurity-specific roles, dates, numbers, or other firm-specific facts from the ✓ IS list, making it generic boilerplate.


reasoning: The paragraph details the company's internal incident response and recovery frameworks, including testing through simulations and tabletop exercises, which aligns with Risk Management Process as it focuses on the company's own IR planning. It contains no named standards, cybersecurity-specific roles, dates, named programs, or other firm-specific facts, rendering it Generic Boilerplate.


reasoning: This paragraph describes generic risk oversight by the board of directors and executive officers without any mention of cybersecurity, qualifying as non-substantive non-cybersecurity content.


reasoning: The paragraph centers on the Board of Directors as the grammatical subject, detailing its receipt of quarterly reports from the CISO and CIO on cybersecurity threats, risks, and mitigation processes, which aligns with Board Governance for oversight and briefing cadence.


reasoning: This paragraph lists generic cybersecurity threats and vulnerabilities such as malware, ransomware, phishing, and social engineering without referencing any company-specific processes, incidents, governance, or strategies, qualifying as non-substantive boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion stating no cybersecurity incidents have materially affected the company, with no incident narrative or description of events, fitting Strategy Integration per tiebreakers. It contains no specific facts, frameworks, or unique details, making it Generic Boilerplate.


reasoning: The paragraph centrally describes the company's process for reviewing and monitoring key third-party IT service providers' cybersecurity measures, including use of a specific tool, qualifying as Third-Party Risk rather than a mere component of internal processes.


reasoning: The paragraph describes general steps in the eradication phase of incident response, which falls under the company's internal risk management processes including IR planning. It contains no description of a specific incident or other category elements.


reasoning: The paragraph describes the company's own cybersecurity program as a critical element of its overall risk management approach, directly aligning with Risk Management Process for internal processes. It contains no specific facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph centers on the Board receiving regular updates on cybersecurity risks, key risk indicators, test results, and threat management from the Audit Committee and Cybersecurity team, with the Board as the grammatical subject, aligning directly with Board Governance.


reasoning: The paragraph centers on the 'internal cybersecurity coordinator' as the grammatical subject, detailing its responsibilities for risk assessment and management, collaboration with the IT team, and reporting to the CEO, which aligns with 'Management Role' for identifying roles and reporting lines.


reasoning: This paragraph describes elements of the company's own cybersecurity programs, including investment in threat intelligence, engagement in forums, and use of external experts for assessments and testing, which aligns with Risk Management Process as it focuses on internal processes rather than board oversight, management roles, or third-party risk centrally.


reasoning: The paragraph states no significant cybersecurity breaches or associated costs occurred in specific past periods, which is a standalone materiality conclusion without any incident narrative, fitting Strategy Integration. It contains two specific dates (December 31, 2023 and 2022), qualifying as Quantified-Verifiable.


reasoning: The paragraph focuses on the qualifications and experience of the company's information technology team in cybersecurity, which aligns with Management Role as it describes the team's expertise handling cyber matters, even though no specific roles like CISO are named. It does not fit other categories like Board Governance or Risk Management Process, which require oversight or internal processes as the main topic.


reasoning: The paragraph focuses on the identification and role of the CISO (CFO serving as CISO) in implementing and maintaining cybersecurity processes, making 'Management Role' the most applicable category as management roles are the grammatical subject.


reasoning: Paragraph describes use of third-party email and cloud storage services with built-in cybersecurity protections as part of the company's systems, fitting internal risk management processes where vendors are a component rather than the central oversight topic. No substantive details on vendor management, incidents, or other categories.


reasoning: The paragraph focuses on specific management roles (CIO and VP of Information Security) as the primary subjects responsible for overseeing the cybersecurity program, directly matching the 'Management Role' category definition.


reasoning: Paragraph identifies specific management roles (CIO, Director of IT Security) and their qualifications/experience, making Management Role the best fit as roles are the grammatical subject and focus. Contains cybersecurity-specific roles and a quantified experience metric, qualifying as Firm-Specific but lacking two hard verifiable facts (e.g., no dates, named firms/products) for Quantified-Verifiable.


reasoning: The paragraph discusses the company's internal incident response plan, including ongoing review, refinement, and updates based on lessons learned, which aligns with Risk Management Process as it focuses on the company's own IR planning and processes. No actual incidents, board, management roles, vendors, or strategy elements are described.


reasoning: The paragraph focuses on the Board and Audit Committee receiving regular reports from management on cybersecurity risks and incidents, which directly matches Board Governance as the board/committee is the grammatical subject describing oversight.


reasoning: The paragraph primarily describes how the CSO and CISO (management roles) stay informed on risks and communicate updates, including reporting lines to a committee, making Management Role the best fit despite secondary mention of board oversight. Tiebreaker favors management roles as the main grammatical subject over brief board reference.


reasoning: This paragraph provides a standalone materiality conclusion stating no material cybersecurity incidents as of specific dates, with no incident narrative or description of events. It fits Strategy Integration per tiebreakers for materiality assessments without incident details.


reasoning: The paragraph states there were no material cybersecurity incidents or expenses in the last three fiscal years, which is a standalone materiality conclusion without any incident narrative, aligning with Strategy Integration. It contains no specific facts from the ✓ IS list or named standards, resulting in Generic Boilerplate specificity.


reasoning: The paragraph details the company's own internal processes for employee training and phishing simulations to enhance cybersecurity awareness, aligning with Risk Management Process. It contains no named frameworks, specific roles, dates, numbers, or other firm-unique facts, making it Generic Boilerplate.


reasoning: The paragraph describes cyber insurance coverage to mitigate financial losses from cyber incidents, directly aligning with Strategy Integration which includes cyber insurance. It lacks any firm-specific facts, named standards, or verifiable details, making it generic boilerplate.


reasoning: The paragraph describes the company's approach to developing, implementing, and maintaining cybersecurity measures to protect information systems and data, which aligns with internal risk management processes. It contains no specific facts, named standards, or unique details, making it generic boilerplate.


reasoning: The paragraph describes the company's own internal processes for identifying, assessing, and managing cybersecurity risks to its systems and data, which directly matches Risk Management Process. It includes a brief mention of third-party hosted services as part of internal systems, not as the central topic of vendor oversight.


reasoning: This paragraph describes the company's own internal strategies for assessing, identifying, and managing cybersecurity risks, including traffic monitoring and user training, aligning with Risk Management Process. No named frameworks, roles, dates, tools, or other specific facts are present, resulting in Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity processes, including threat analysis, policy definition, implementation, monitoring, and incident response by cybersecurity professionals, which aligns with Risk Management Process. It contains no specific facts, named standards, roles, or details unique to the company, making it Generic Boilerplate.


reasoning: The paragraph focuses on the Board of Directors' oversight of the cybersecurity program through periodic updates and annual discussions in enterprise risk management, directly matching the Board Governance category as the board is the grammatical subject.


reasoning: The paragraph identifies responsibilities of specific executives (CFO, COO, CEO) for managing cybersecurity risks and policies, with management roles as the grammatical subject, fitting the Management Role category. No cybersecurity-specific roles, named committees, dates, or other firm-specific facts are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the company's own internal cybersecurity risk management system for identifying, assessing, mitigating risks, and protecting information assets, fitting Risk Management Process. No named frameworks, roles, dates, or other specific facts are present, making it Generic Boilerplate.


reasoning: The paragraph describes management's monitoring of prevention, detection, mitigation, and remediation of cybersecurity incidents, which aligns with the company's own risk management processes, with third-party notifications as a component rather than the central topic. No cybersecurity-specific roles, named committees, dates, firms, or standards are mentioned, making it generic boilerplate.


reasoning: The paragraph describes the company's own internal processes for cybersecurity awareness training and risk management of third-party providers, including due diligence and monitoring, making Risk Management Process the best fit; vendors are a component of internal processes, not the central topic.


reasoning: This paragraph directly addresses the day-to-day management of cybersecurity by IT staff, their lack of specialized training, and considerations for enhancement or outsourcing, fitting the 'Management Role' category which covers management roles and qualifications.


reasoning: This paragraph describes the company's internal process of providing regular training to employees and contractors on cybersecurity threats and policies, which is part of their risk management practices. No specific facts, named standards, or unique details are present, making it generic boilerplate.


reasoning: The paragraph describes the company's establishment of an internal multi-disciplinary team for cybersecurity awareness, training, and information sharing, which is part of its own risk management processes. No board, management roles, incidents, or third-parties are the focus.


reasoning: This paragraph outlines generic goals for cybersecurity incident response without referencing any specific processes, roles, incidents, or company-unique details, resulting in no substantive disclosure.


reasoning: The paragraph describes the company's own internal Incident Response Plan (IRP) and its testing via annual tabletop exercises, which aligns with Risk Management Process focusing on IR planning and internal processes.


reasoning: The paragraph describes the company's implementation of a multi-layered cybersecurity program with administrative, physical, and technical measures, along with an incident response plan to inform management, which aligns with internal risk management processes. It contains no specific facts from the ✓ IS list or named standards, resulting in generic boilerplate.


reasoning: The paragraph describes the company's planned internal processes for identifying, assessing, and managing cybersecurity risks as part of its broader risk management system, fitting Risk Management Process. It includes a unique named system (BDTP TM), qualifying as Firm-Specific with no named frameworks or additional verifiable facts.


reasoning: This paragraph details the company's own internal cybersecurity and IT programs, including policies, procedures, assessments, monitoring, response plans, and testing of controls, which fits Risk Management Process as it focuses on internal processes. No specific facts, named frameworks, roles, or unique details are present, making it Generic Boilerplate.


reasoning: This paragraph states a materiality conclusion about the incident's lack of likely impact on financial condition or results of operations, without any incident narrative or description, aligning with Strategy Integration per tiebreakers for financial/materiality discussions.


reasoning: The paragraph discusses seeking reimbursement from cybersecurity insurance for costs related to a cyber incident, focusing on financial impact and insurance without any incident narrative or description of the event, which aligns with Strategy Integration per tiebreakers. No specific facts, dates, amounts, or named entities qualify it beyond generic boilerplate.


reasoning: This paragraph provides a standalone materiality conclusion stating no cybersecurity threats materially affected the company in 2024, with no incident narrative or description of events, fitting Strategy Integration. The cross-reference to Risk Factors is ancillary and does not change the primary focus on materiality assessment.


reasoning: This paragraph describes ongoing incident response actions (forensic analysis and investigation) for a specific cybersecurity incident referenced as 'the incident,' fitting Incident Disclosure. No specific details like dates, scope, or impacts are provided, making it generic boilerplate with no qualifying specific facts.


reasoning: The paragraph provides a standalone materiality conclusion regarding the financial and operational impact of 'the Incident' without any description of the event itself, aligning with Strategy Integration per tiebreakers. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes ongoing incident response actions (system restoration, retaining experts, law enforcement coordination, regulatory notifications) and operational disruption in the context of a cybersecurity incident, fitting Incident Disclosure. No specific details like dates, named entities, or quantifiable impacts are provided, making it generic boilerplate.


reasoning: This paragraph provides a materiality conclusion regarding the financial impact of an incident without describing the event itself, fitting Strategy Integration per tiebreakers. It contains no specific facts, named standards, or unique details, making it Generic Boilerplate.


reasoning: The paragraph discusses financial and operational impacts (no material disruption, potential losses from revenue, expenses, remediation, penalties, litigation) of 'the Incident' without any incident narrative, description of events, or response actions, fitting Strategy Integration per tiebreakers for materiality conclusions without event details.


reasoning: The paragraph discusses the potential material impact of an incident on financial condition and ongoing assessment without any incident narrative or description of events, aligning with Strategy Integration per tiebreakers for materiality conclusions without event details. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph describes the company's cybersecurity insurance policy and its coverage for various costs, which aligns with Strategy Integration as it focuses on financial and insurance aspects without referencing a specific incident or event narrative.


reasoning: The paragraph provides a materiality assessment of an incident's impact on operations and financial condition without any narrative description of the event, aligning with Strategy Integration per tiebreakers for materiality conclusions. No specific facts, named standards, or verifiable details are present, resulting in Generic Boilerplate.


reasoning: The paragraph identifies specific individuals in management, including the Senior Director of IT and CFO, responsible for implementing and maintaining cybersecurity processes, making management roles the focus.


reasoning: The paragraph provides a materiality assessment of a cybersecurity incident without describing the event itself, focusing solely on its lack of material impact on operations or financial condition, which fits Strategy Integration per tiebreakers. No specific facts are present, confirming Generic Boilerplate specificity.


reasoning: The paragraph discusses ongoing business and financial risks (litigation, customer behavior, regulatory scrutiny, insurance costs) stemming from a past cybersecurity incident without describing the event itself, aligning with Strategy Integration per tiebreakers for financial/insurance impacts lacking incident narrative.


reasoning: This paragraph discusses waivers under credit and lease agreements with no reference to cybersecurity, qualifying as non-cybersecurity content under None/Other.


reasoning: The paragraph identifies specific cybersecurity-related management roles (chief technology officer and senior director of cybersecurity and compliance), their qualifications (certifications), and reporting lines, aligning with Management Role; the Audit Committee mention is secondary and the risk program description is generic boilerplate.


reasoning: The paragraph describes the scope of a previously disclosed cybersecurity incident (threat actor access and exfiltration of limited data including some PII) and ongoing response actions (notifications to affected parties and regulators), fitting Incident Disclosure as it references a real event with narrative details on what happened and response. No specific facts qualify under the ✓ IS list, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes incident response actions, specifically notifications to law enforcement and regulatory bodies about 'the matter' (implying a cybersecurity incident), which fits Incident Disclosure as it includes response actions referencing a real event. No descriptive details of the incident itself, but the category encompasses such actions.


reasoning: The paragraph provides a materiality assessment of an incident's impact on operations and financial condition without any incident narrative, description of events, or response actions, aligning with Strategy Integration per tiebreakers. It lacks any specific facts, named standards, or verifiable details, resulting in Generic Boilerplate specificity.


reasoning: This paragraph references an ongoing 'disruption' and 'incident' but provides no narrative, dates, scope details, or response actions, instead directing to an external status page, which qualifies as a cross-reference with no substantive disclosure.


reasoning: The paragraph provides a materiality assessment of an incident's impact on operations and financials without any description of the event, response, or scope, aligning with Strategy Integration per tiebreakers for financial/materiality discussions absent incident narrative.


reasoning: This paragraph provides a standalone materiality conclusion regarding a cybersecurity incident's impact on financial condition and operations, without any incident narrative or description, fitting Strategy Integration per tiebreakers. No specific facts, frameworks, or unique details are present, making it generic boilerplate.


reasoning: The paragraph discusses the materiality assessment of an incident on operations and financial condition without describing the event itself, fitting Strategy Integration per tiebreakers for financial impact and materiality conclusions. No specific facts or named standards are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph details incident response actions, specifically notifying law enforcement and regulators about 'the matter,' which references a real cybersecurity incident in the context of Item 1.05. It fits Incident Disclosure as it describes response actions without narrative of the event itself, dates, or scope.


reasoning: The paragraph discusses the lack of material operational disruption and ongoing evaluation of financial, legal, reputational impacts, and remediation costs of 'the incident' without describing the event itself, fitting Strategy Integration per tiebreakers for materiality conclusions without incident narrative.


reasoning: Paragraph describes executive resignation and interim CEO appointment in a subsidiary with no reference to cybersecurity incidents, risks, or processes.


reasoning: The paragraph discusses financial impact and insurance reimbursement for a cybersecurity incident without describing the event itself, fitting Strategy Integration per tiebreakers for financial cost/insurance without incident narrative. No specific facts, frameworks, or verifiable details are present, making it Generic Boilerplate.


reasoning: The paragraph describes response actions taken in response to a specific cybersecurity incident, including closing unlawful access and notifying impacted customers, fitting the Incident Disclosure category which includes incident response actions. No firm-specific facts, dates, names, or standards are present, making it Generic Boilerplate.


reasoning: The paragraph describes response actions to a specific cybersecurity incident, including containment, restoration of the core IT environment, and progress on business operations, fitting the Incident Disclosure category as it references a real event and operational impact without focusing on financials or processes.


reasoning: The paragraph discusses the material financial impact of 'the incident' without describing the event itself, ongoing investigation, or response actions, fitting Strategy Integration per tiebreakers for materiality conclusions without incident narrative. No specific facts, frameworks, or unique details are present, confirming Generic Boilerplate.


reasoning: The paragraph describes response actions (containment, system restoration, resuming operations) to a specific cybersecurity incident, fitting Incident Disclosure criteria which includes incident response actions referencing a real event. No firm-specific or verifiable facts are present, making it generic boilerplate.


reasoning: The paragraph details a real cybersecurity incident with specific dates of notification and confirmation, exposure of customer information by a third-party provider, directly matching Incident Disclosure criteria including dates and scope; not Third-Party Risk as it centers on incident narrative rather than oversight processes.


reasoning: This paragraph describes the ongoing status of an incident investigation, undetermined data scope, and response actions including coordination with a cyber insurance provider, fitting Incident Disclosure as it references response to a real event without financial/materiality focus.


reasoning: The paragraph references an ongoing investigation into 'the incident' but provides no description of the event itself, focusing instead on a materiality conclusion regarding financial condition and operations, which fits Strategy Integration per tiebreakers. No specific facts, named entities, dates, or standards are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes ongoing investigation, scope assessment of exfiltrated personal information, and planned notifications related to a specific cybersecurity incident, fitting Incident Disclosure as it references response actions and affected data scope without financial or materiality details.


reasoning: The paragraph discusses the immaterial impact of 'the incident' on operations and financial condition without describing the event itself, fitting Strategy Integration per tiebreakers for materiality conclusions without incident narrative.


reasoning: Paragraph describes operational impacts and scope of affected systems (online ordering disruptions in parts of the US, shops open, deliveries uninterrupted) from a cybersecurity incident, fitting Incident Disclosure criteria for scope and operational impact without detailing the event itself.


reasoning: The paragraph discusses a materiality assessment of an incident's potential financial impact without any incident narrative or description, fitting Strategy Integration per tiebreakers for standalone materiality conclusions. No specific facts, standards, or unique details present, confirming Generic Boilerplate specificity.


reasoning: The paragraph describes the specifics of what occurred during a cybersecurity incident, including unauthorized access, data exfiltration, and encryption of non-production systems, fitting the Incident Disclosure category as it provides a narrative of a real event without focusing on financial impacts or processes. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph addresses monitoring the timing and materiality of an ongoing incident without any description of the event, response actions, or scope, aligning with Strategy Integration per tiebreakers for materiality discussions without incident narrative.


reasoning: The paragraph discusses the assessment of financial and operational materiality from an incident without any description of the event itself, aligning with Strategy Integration per tiebreakers for materiality conclusions lacking incident narrative. No specific facts, frameworks, or details are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes ongoing incident response actions (investigation and forensic analysis) and potential scope (whether PII was taken) related to a specific cybersecurity incident involving threat actors, fitting Incident Disclosure. No specific facts from the ✓ IS list or hard verifiable elements are present, resulting in Generic Boilerplate.


reasoning: The paragraph describes incident response actions (mailing notification letters) and scope of potentially affected data (personal information), referencing a real event via 'the investigation and findings,' fitting Incident Disclosure. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: Paragraph describes a real cybersecurity incident with a specific date, system outage details, and response actions (activating incident response team), directly matching Incident Disclosure criteria. Contains one hard verifiable fact (specific date), qualifying as Firm-Specific but not Quantified-Verifiable due to lacking a second verifiable fact.


reasoning: This paragraph describes a real cybersecurity incident with a specific date, the event (systems outage caused by attack), and response actions (activated incident response team), directly matching Incident Disclosure criteria.


reasoning: This paragraph describes the operational scope and impact of a specific cybersecurity incident (affected functions like shipping, manufacturing, and back office) along with response actions (temporary measures and restoration), fitting Incident Disclosure. No specific facts from the ✓ IS list are present, making it Generic Boilerplate.


reasoning: Paragraph details post-incident response actions (system restoration), affected scope (IT systems and data), and operational impacts (minor ongoing effects) for a referenced cyber incident, directly matching Incident Disclosure criteria. No verifiable facts such as dates, named entities, or quantities are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes the response to a cybersecurity incident, including activation of the response process and determination that a fourth-party vendor compromise caused the incident, fitting the Incident Disclosure category as it provides a narrative of what happened and response actions for a real event. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: This paragraph describes a specific cybersecurity incident, including the exact date the Company became aware of unauthorized third-party access to certain systems, which directly matches the Incident Disclosure category criteria for referencing a real event with details like dates and access.


reasoning: The paragraph discusses the financial impacts and costs of a cyber incident without describing the event itself, aligning with Strategy Integration per tiebreakers for financial cost discussions lacking incident narrative. No specific facts from the ✓ IS list are present, confirming Generic Boilerplate specificity.


reasoning: This paragraph describes what happened in the cybersecurity incident (threat actor access to a portion of IT systems containing sensitive personal information) and response actions (notifications to affected parties and regulators), directly matching Incident Disclosure criteria for incident narrative and scope.


reasoning: The paragraph assesses the materiality and financial impact of a cybersecurity incident on quarterly and overall results without describing the incident itself, event details, scope, or response actions, aligning with Strategy Integration per tiebreakers for financial/materiality discussions lacking incident narrative.


reasoning: The paragraph provides a materiality assessment of a cybersecurity incident's impact on operations and financial condition without describing the incident itself, aligning with Strategy Integration per tiebreakers for financial/materiality discussions lacking event narrative.


reasoning: The paragraph assesses the potential material impact of an incident on financial condition and results of operations without any incident narrative or description, aligning with Strategy Integration per tiebreakers for materiality discussions without event details.


reasoning: Paragraph describes operational impact (primary website inaccessible during disruption) and response action (creation of special incident website), referencing a real event, fitting Incident Disclosure. Contains one firm-unique named system (specific URL), qualifying as Firm-Specific but not Quantified-Verifiable (only one hard fact).


reasoning: This paragraph describes a specific cybersecurity incident, including the date of detection and the nature of the fraudulent attempt by unknown persons, directly matching Incident Disclosure criteria for event narrative.


reasoning: This paragraph describes the scope and operational impact of a cybersecurity incident, including limited access to business applications and financial/operating reporting systems for approximately six weeks, which matches Incident Disclosure criteria for referencing a real event's effects. No specific facts from the ✓ IS list are present, and 'approximately six weeks' is an approximate duration that does not qualify as a hard verifiable fact, resulting in Generic Boilerplate specificity.


reasoning: This paragraph assesses the materiality of an incident's impact on operations and financial condition without any incident narrative, description of events, or response actions, aligning with Strategy Integration per tiebreakers for financial/materiality discussions. It contains no specific facts, named standards, or verifiable details, making it Generic Boilerplate.


reasoning: Paragraph describes incident response actions (notifying regulators and working with law enforcement) tied to a specific unauthorized access event, fitting Incident Disclosure criteria for response actions to a real incident. No specific facts from the ✓ IS list (no dates, roles, named firms/tools, numbers, or unique programs); 'Targus' is a company self-reference (excluded per ✗ NOT list), and regulators/law enforcement are generic.


reasoning: Paragraph describes a real cybersecurity incident with date, unauthorized activity on IT systems, and response actions (investigate, contain, remediate), directly matching Incident Disclosure criteria. No focus on governance, processes, vendors, or strategy.


reasoning: The paragraph describes incident response actions (temporary measures like manual processing and alternative channels) and operational continuity efforts during system restoration, fitting Incident Disclosure as it references response to a real event without detailing the incident itself. No specific facts from the ✓ IS list are present, resulting in Generic Boilerplate specificity.


reasoning: The paragraph details the company's internal processes for evaluating cybersecurity incidents, escalation procedures, and incident response and business continuity plans, which aligns with Risk Management Process. The CSO is a cybersecurity-specific role, qualifying as a firm-specific fact, but there are no named frameworks or two or more hard verifiable facts.


reasoning: The paragraph focuses on the company's own internal processes for monitoring, developing, and mitigating cybersecurity risks through IT networks and infrastructure, aligning with Risk Management Process. It contains no named frameworks, roles, dates, or other specific facts, making it Generic Boilerplate.


reasoning: The paragraph details the company's internal processes for threat assessment, layered security, training, tool usage, third-party assessments, and vendor risk management, focusing on their own risk management practices with vendors as a component. References to NIST, ISO, and SOC standards qualify it as Sector-Adapted, but no firm-specific facts from the ✓ IS list are present.


reasoning: The paragraph outlines the company's own cybersecurity program, focusing on internal processes like governance structures, incident response planning, cross-functional approaches, technical safeguards, third-party risk as a component, and employee training, which aligns with Risk Management Process. Board and management mentions support but do not dominate the content.


reasoning: The paragraph focuses on the Board's and Risk Committee's oversight of cybersecurity risks, including their roles in reviewing ERM policies, engaging with management/consultants, and reporting cadences, making Board Governance the clear fit. No other category dominates as the grammatical subjects are board-level entities.


reasoning: This paragraph describes the company's own internal cybersecurity risk management processes, including adoption of the CIS framework, regular risk assessments integrated with ERM, infrastructure design, dedicated personnel, and training programs. The brief mention of the Technology Committee reviewing assessments is incidental, not the grammatical subject or central focus.


reasoning: Paragraph states no material cybersecurity risks or incidents affected the company in fiscal 2024, including impacts on business strategy, operations, or financial condition, which is a standalone materiality conclusion fitting Strategy Integration. It includes one specific fact (fiscal 2024) qualifying as Firm-Specific, with no named frameworks or additional verifiable facts.


reasoning: This paragraph is a cross-reference to a press release attached as an exhibit, providing no substantive cybersecurity disclosure itself, which fits None/Other per guidelines including cross-references.


reasoning: The paragraph details the company's internal cybersecurity processes, including framework adoption (NIST CSF), security controls, awareness training, third-party oversight as a program component, monitoring, and resiliency planning. Third-party risk is mentioned as part of the internal risk management program, not as the central topic.


reasoning: The paragraph primarily describes the CISO and CTO's roles, responsibilities, reporting structure, and detailed professional qualifications, aligning with Management Role criteria where management roles are the grammatical subjects. Brief mentions of processes and Audit Committee do not overshadow the focus on these specific executives.


reasoning: Paragraph provides generic boilerplate description of reliance on IT systems and broad cyber risks without referencing board oversight, management roles, internal processes, incidents, third-parties centrally, or strategy integration; qualifies as non-substantive disclosure under None/Other.


reasoning: The paragraph centers on the specific internal Risk Management Team's composition, roles, monitoring activities, and reporting to the Audit Committee on cybersecurity risks, fitting Management Role as the main focus despite mentions of board oversight. Team composition qualifies as a firm-specific fact, but no named frameworks, dates, third-parties, or quantified metrics reach higher specificity levels.


reasoning: The paragraph details the company's own internal cybersecurity processes, including threat identification, technical safeguards, vulnerability assessments, incident response planning, third-party risk as one component, and employee training, fitting Risk Management Process. No specific facts from the ✓ IS list are present, making it generic boilerplate.


reasoning: The paragraph primarily describes the company's internal cybersecurity processes, including monitoring, training, penetration testing, and vendor risk evaluation as a component, rather than focusing centrally on vendor oversight or management roles. Specific roles and a yearly timeframe provide firm-unique details beyond generic practices or named standards like SOC 1/2.


reasoning: The paragraph details the company's own internal cybersecurity risk management program, including policies, standards, processes for assessing and managing risks, and resource allocation to meet regulatory requirements, aligning with Risk Management Process. It contains no specific facts from the ✓ IS list or named frameworks, resulting in Generic Boilerplate specificity.


reasoning: This paragraph contains only generic, forward-looking boilerplate language about cybersecurity threats, vulnerabilities, and potential impacts, with no substantive disclosure on governance, processes, incidents, or strategies.


reasoning: The paragraph details the company's internal cybersecurity risk management processes, including multi-layered defense, monitoring, information sharing, third-party assessments as a component, policies, training, and supplier engagement, making 'Risk Management Process' the most applicable category. Vendor-related elements are integrated as parts of the overall internal approach, not the central topic. No specific facts from the ✓ IS list are present, and no named frameworks qualify it beyond Generic Boilerplate.


reasoning: The paragraph primarily describes the company's internal cybersecurity risk management processes, including adoption of the NIST framework, risk assessment, monitoring, controls, testing, vendor due diligence as a component, employee training, and expert consultations. Management roles are mentioned but are not the grammatical subject or central focus.


reasoning: The paragraph primarily identifies and describes management roles (IT Manager, General Counsel, CEO, COO), their qualifications, experience, reporting lines, and involvement in cybersecurity oversight and crisis response, making 'Management Role' the most applicable category. It details firm-specific elements like the IT Steering Committee and Cyber Incident Response Plan, qualifying as Firm-Specific without reaching Quantified-Verifiable thresholds (no two hard verifiable facts like dates or named external firms/tools).


reasoning: The paragraph details the company's own internal processes for risk identification, mitigation using the NIST Framework, monitoring, protection measures, incident response planning (IRP, BCP), enterprise risk assessment, and ongoing programs, making Risk Management Process the best fit; brief Board sharing is not central.


reasoning: The paragraph identifies and details qualifications, experience, and reporting for cybersecurity-specific roles like vCISO, analysts, engineers, and director of information security, with management oversight, fitting Management Role. It emphasizes personnel rather than board governance, processes, or third-party vendor oversight.


reasoning: The paragraph describes the company's overall cybersecurity program as part of its ERM approach, detailing internal processes across key areas like governance, collaboration, technical safeguards, incident response, third-party risk management (as a component), and training. Board and management roles are mentioned briefly but are not the grammatical subjects or central focus.


reasoning: The paragraph details the company's own internal cybersecurity program, including risk assessment processes, monitoring, training, incident response, third-party risk management as a component, and ERM integration, making Risk Management Process the best fit. Board oversight and a management role are mentioned briefly but are not central.


reasoning: The paragraph describes the company's internal cybersecurity processes, including threat identification, technical safeguards, incident response planning, third-party risk management as a component, and employee training, making 'Risk Management Process' the most applicable category. Vendor oversight is mentioned but not central, per tiebreakers.


reasoning: The paragraph centers on the Chief Information Officer's identification, qualifications, experience, certifications, reporting cadences to management and board, and role in the Risk Report process, aligning with 'Management Role'. Board and Audit Committee mentions are secondary as recipients of reports.


reasoning: The paragraph includes a standalone materiality conclusion that past incidents have not had a material impact, along with discussions of potential business and financial effects, without any incident narrative or description of events, aligning with Strategy Integration per tiebreakers. It contains no specific facts, named standards, or unique details qualifying for higher specificity.


reasoning: The paragraph focuses on the Board of Directors and Audit Committee's oversight, review, and assessment of cybersecurity risks, with the board/committee as the grammatical subjects, aligning with Board Governance. It includes boilerplate materiality language and a cross-reference but no incident details or other central topics. No qualifying specific facts or named standards are present, confirming Generic Boilerplate.


reasoning: The paragraph details the company's internal incident response processes, including named plans, teams, training, assessments, and tools, making Risk Management Process the best fit as it focuses on the company's own cybersecurity practices. Vendor mentions are incidental to internal oversight, not central.


reasoning: The paragraph details the company's internal cybersecurity processes, including monitoring, detection, protections, trainings, testing, vulnerability scanning, penetration testing, third-party risk management via a risk register, and insurance, making 'Risk Management Process' the best fit as third-party aspects are components of internal processes rather than the central topic.


reasoning: Paragraph briefly mentions generic past non-material cybersecurity incidents and provides a materiality conclusion without describing any specific event, aligning with Strategy Integration per tiebreakers; includes forward-looking disclaimers and cross-reference to risk factors.


reasoning: The paragraph details the company's internal cybersecurity monitoring, tools, response procedures, future strategy, and employee notification protocols, aligning with Risk Management Process as the central topic of own processes. Third-party services are mentioned as tools utilized internally, not as central vendor oversight.


reasoning: The paragraph describes the company's own internal technical, physical, and organizational safeguards, processes, and policies for managing cybersecurity risks, including monitoring, incident response, training, and risk assessments, which aligns with Risk Management Process. Vendor management is a minor component, not central, and no firm-specific facts, named roles, dates, or standards are present, making it Generic Boilerplate.


reasoning: The paragraph details the company's own internal cybersecurity processes, including enterprise-wide monitoring, use of a third-party service as a component, the Cybersecurity Incident Response Plan, and engagements with external experts for vulnerability management and testing, making Risk Management Process the best fit. Third-party elements are integrated into internal processes rather than being the central topic.


reasoning: The paragraph leads with the Board of Directors and Risk Committee overseeing risk management processes, including cybersecurity, fitting Board Governance as the board/committee is the grammatical subject for oversight. Subsequent details describe internal processes but do not override the primary board focus.


reasoning: The paragraph provides a standalone materiality conclusion stating no cybersecurity threats with material impact occurred during the year ended December 31, 2024, and discusses potential business and financial impacts of hypothetical future incidents, aligning with Strategy Integration per tiebreakers for materiality assessments without incident narrative.


reasoning: The paragraph primarily describes the company's own risk assessment and cybersecurity risk management programs, including processes to identify and manage threats, fitting 'Risk Management Process'; the materiality statement is secondary and lacks incident details, so it does not shift to 'Strategy Integration' or 'Incident Disclosure'.


reasoning: The paragraph focuses on identifying specific management leaders (e.g., chief digital officer, CIO, CISO) and their qualifications, reporting within the technology group, aligning with 'Management Role'. No board oversight, processes, incidents, or vendors are central.