reasoning: The paragraph's primary content is a detailed narrative of the MOVEit/PBI cybersecurity incident — what happened, when, scope of data exposure, and response actions. While it includes a materiality conclusion and cross-reference at the end, the incident description dominates. Multiple QV-eligible hard facts: specific date (June 22, 2023), named third-party firm (PBI), named product (MOVEit), and quantified impact (~2.5-2.7 million affected individuals).

thinking:
This is a complex paragraph that covers multiple topics. Let me analyze it carefully.

The paragraph describes:
1. Incident response procedures (DSCP)
2. A specific incident - MOVEit/PBI breach disclosed June 22, 2023
3. Details of the incident - unauthorized data acquisition, ~2.5-2.7 million policyholders affected
4. Impact assessment - no material impact on systems or operations
5. Materiality conclusion
6. Cross-reference to Risk Factors

The dominant content is clearly the incident narrative - it describes what happened, when, the scope, the response, and the impact. This is Incident Disclosure.

I'm seeing several concrete, verifiable facts here: the Form 8-K filing date of June 22, 2023, the third-party vendor PBI, the MOVEit transfer system, and the specific quantified impact of 2.5 to 2.7 million policyholders. That's well over the threshold for Quantified-Verifiable classification.

fact: Form 8-K filed on June 22, 2023

fact: PBI, a third-party vendor

fact: MOVEit file transfer system

fact: Approximately 2.5 to 2.7 million policyholders' or other customers' personal information exposed


content_category: None/Other

category_confidence: high

specificity_confidence: high

reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors, with the lengthy quoted risk factor title serving as a pointer rather than substantive disclosure. There is no materiality assessment (no 'have not materially affected' or similar conclusion) — it simply says cybersecurity threats 'may materially affect' and directs readers elsewhere. This is a pure cross-reference with no independent cybersecurity disclosure content.

provider: anthropic

generationId: agent-sdk

stage: benchmark


content_category: Incident Disclosure

reasoning: The paragraph describes a specific cybersecurity incident — a phishing attack resulting in an unauthorized payment — including timeline, response actions, fund recovery, and remediation controls implemented afterward. Three hard verifiable facts (two specific dates and a dollar amount) qualify it as Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

Content: Describes a specific phishing attack incident - date, amount, what happened, investigation, recovery, and remediation actions taken.

Category: This is clearly Incident Disclosure - it describes what happened (phishing attack), when (April 28, 2023), scope ($54,300 payment), response (investigation, fund recovery), and remediation (additional controls).

Specificity: Let me count hard verifiable facts:
- April 28, 2023 (specific date)
- $54,300 (dollar amount)
- June 29, 2023 (specific date)

- That's 3 QV-eligible facts, so this qualifies as Quantified-Verifiable.

fact: April 28, 2023 — date incident identified

fact: $54,300 — amount of incorrect payment

type: quantified

fact: June 29, 2023 — date funds recovered


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


category_confidence: medium

reasoning: The paragraph's dominant content is a description of an actual cybersecurity incident — the MOVEit breach — including the investigation with PBI, the scope of affected individuals (2.5-2.7M), the type of data exposed (SSNs), and response actions. While it opens with a brief DSCP procedural reference and closes with a materiality assessment, the incident narrative occupies the majority of the paragraph and is its primary communicative purpose. Multiple QV-eligible hard facts: specific date (Feb 29, 2024), named firm (PBI), named product (MOVEit), and specific headcount (~2.5-2.7M).

thinking:
Let me analyze this paragraph carefully.

Content: Describes the MOVEit incident - notification, investigation with PBI, scope (2.5-2.7M policyholders), data exposed (SSNs), then materiality assessment.

Category: This is tricky. It describes an actual incident (MOVEit), the investigation, the scope, and then concludes with materiality assessment. The paragraph has both Incident Disclosure and Strategy Integration elements. The dominant content: it describes what happened (MOVEit incident, investigation with PBI, 2.5-2.7M affected, SSNs exposed) AND then assesses materiality. The incident narrative takes up significant space, but the paragraph also has a strong materiality conclusion.

Looking at the tiebreakers, the paragraph clearly describes what happened in the incident—the scope, the response actions, the data exposed—which points toward Incident Disclosure. But the real purpose seems to be using the MOVEit example to illustrate how materiality is assessed, making the materiality conclusion the driving force rather than just a supporting detail.

Counting the specific, verifiable facts: February 29, 2024 as the date, PBI as the named investigator, 2.5 to 2.7 million affected policyholders, MOVEit as the system involved, and DSCP as the internal program. That's solid ground for QV-eligible facts, though I need to verify whether all of these meet the specificity threshold.

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

fact: PBI (named third-party firm involved in investigation)

fact: MOVEit (named system/product involved in incident)

fact: approximately 2.5 million to 2.7 million policyholders affected

fact: DSCP (named internal program — Data Security and Cyber Program)


content_category: Risk Management Process

reasoning: The paragraph describes the company's internal information security program — its safeguards, policies, and scope across businesses. The Information Security Officer is mentioned as attribution ('administered by'), but the substantive content is about the program itself, making this Risk Management Process per the person-vs-function test. The ISO title is a cybersecurity-specific role on the IS list, yielding Firm-Specific, but no second hard verifiable fact exists to reach QV.

thinking:
Let me analyze this paragraph.

Content: Describes an information security program administered by an Information Security Officer, covering safeguards and policies across businesses.

Category: The paragraph describes the company's internal security program - safeguards, policies, procedures. The Information Security Officer is mentioned as attribution ("administered by our Information Security Officer"). The bulk is about the program itself. Using the person-vs-function test: remove the ISO mention and it still describes a program. → Risk Management Process.

Specificity:
- "Information Security Officer" - this is a cybersecurity-specific title on the IS list → Firm-Specific
- No other hard verifiable facts (no dates, dollar amounts, named firms, named tools, etc.)

- No named frameworks either, so that's one IS fact total → Firm-Specific (3)

fact: Information Security Officer


content_category: Management Role

reasoning: While the first sentence describes CCDC oversight (Board Governance), the dominant content is about management roles: the incident escalation chain (VP of IT → CIO/CPO → General Counsel → CCDC/Board), the CPO's quarterly presentations, and the CPO's IAPP certifications and experience. The paragraph is primarily about who the people are and how they report, making Management Role dominant. QV is met with IAPP certifications (named certifications) plus over a decade of experience (quantified duration) as two hard verifiable facts.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. CCDC oversight of IT/security risks
2. Incident escalation process (VP of IT → CIO/CPO → General Counsel → CCDC/CEO/Board)
3. Quarterly CPO presentations
4. CPO credentials and experience

The primary content is about management roles and their reporting/escalation structure, with the CCDC mentioned at the start. Let me apply the decision rules.

The CCDC (a named non-generic committee) is the subject of the first sentence, but then the paragraph shifts to describing the escalation chain involving VP of IT, CIO, CPO, General Counsel. The last portion describes the CPO's credentials.

Looking at the structure more carefully, the opening sentence establishes CCDC oversight, but the rest of the paragraph is dominated by management reporting relationships, the escalation procedures for incidents, and details about the CPO's background and qualifications.

When I apply the person-versus-function test, the escalation chain is clearly organizational structure, while the CPO credentials and experience are about the individual holding the role. The weight of the content points to **Management Role** as the primary category.

For specificity, I'm noting that IAPP certifications are named credentials worth flagging for QV eligibility, while the quarterly cadence and decade-plus experience are more general descriptors.

Now I'm reconsidering what counts as QV-eligible. The codebook distinguishes between exact durations like "17 years" versus softer approximations like "over a decade." The certifications themselves—CIPP/E, CIPP/US, CIPM, AIGP—are clearly named and specific, so those qualify. But "over a decade" sits in a gray area: it's more precise than just saying "many years," yet it's not an exact figure. I need to determine whether this soft number meets the threshold for QV eligibility or if it's too vague. a decade" is somewhat vague. I'll count it as one.

So I have at least 2 QV-eligible facts: IAPP certifications + years of experience → Quantified-Verifiable.

Wait, the certifications: "certified by the International Association of Privacy Professionals as an EU, US, and management privacy professional, as well as an artificial intelligence governance professional" - these are CIPP/E, CIPP/US, CIPM, and AIGP certifications from IAPP. These are named certifications. That's one category of QV fact.

"Over a decade" - I'll count this as one QV fact (years of experience).

Two QV-eligible facts → Quantified-Verifiable.

Now I'm cataloging the specific roles and credentials: CCDC committee membership, CIO and CPO titles, VP of IT position, the IAPP certifications, and over a decade of quantified experience all support the Quantified-Verifiable classification.

fact: CCDC (named non-generic committee overseeing IT/security)

fact: Vice President of IT

fact: CIO

fact: CPO (Chief Privacy Officer)

fact: Certified by IAPP as EU, US, and management privacy professional and AI governance professional

fact: Over a decade of privacy, data protection, and information management experience


reasoning: The paragraph describes how the Information Security Program is monitored, evaluated, and adjusted in response to technology changes, threats, and business arrangements. The ISO is mentioned as attribution for who performs these activities, but the substantive content is about program adjustment processes (person-vs-function test: replacing 'The ISO' with 'The Company' leaves the process description intact). The ISO title (Information Security Officer) is a cybersecurity-specific role on the IS list, granting Firm-Specific status, but no second QV-eligible fact exists to reach Quantified-Verifiable.

thinking:
Classify this paragraph.

Content: Describes the ISO monitoring and adjusting the Information Security Program based on various factors. The ISO (Information Security Officer) is mentioned as performing these activities, but the paragraph is about what the program does - monitoring, evaluating, adjusting based on changes. The person-vs-function test: remove "The ISO" and replace with "The Company" - it still makes sense as a process description.

Category: Risk Management Process. The ISO is incidental attribution; the content is about program adjustment activities.

Specificity: "ISO" = Information Security Officer - this is a cybersecurity-specific title on the IS list. That's one fact → Firm-Specific. No QV-eligible facts (no dates, dollar amounts, named firms, named tools, etc.).

The ISO title is the only specific fact here, confirming this is Firm-Specific with no qualifying vocabulary elements.

fact: ISO (Information Security Officer)


content_category: Board Governance

reasoning: The paragraph describes the board's oversight mechanism — how the Board of Directors receives cybersecurity information from the ISO, including what topics are discussed (risk assessment, testing results, security breaches, recommendations). While the ISO is the grammatical subject of the first sentence, the paragraph's primary communicative purpose is the board-level information flow and oversight cadence, making Board Governance dominant. The ISO (cybersecurity-specific title) is on the IS list, pushing specificity to Firm-Specific; the Interagency Guidelines is a named standard but the role title alone already qualifies. No two QV-eligible hard facts are present.

thinking:
Let me analyze this paragraph.

The paragraph describes the ISO (Information Security Officer) reporting to the Board of Directors. Let me determine the category and specificity.

Category: The grammatical subject is "the ISO" who "reports to the Board of Directors." This is about the reporting relationship between a management role and the board. The ISO is the primary actor here - reporting to the board. Per Rule 2, "Management role reports TO the board" → Management Role. But wait - let me re-read. "The ISO reports to the Board of Directors the overall status..." - the ISO is the grammatical subject performing the action. Per the tiebreaker table: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor).

Actually, I'm second-guessing myself here. The ISO is clearly the one doing the reporting, making them the primary actor, which points to Management Role. But I need to look at what the paragraph is actually emphasizing - is it the reporting structure itself, or the board's oversight responsibilities? The ISO is the grammatical subject performing the action of reporting, so by Rule 2, this should be Management Role. The ISO is the grammatical subject, which points to Management Role, but this is really about the reporting cadence and what gets communicated to the board rather than the ISO's qualifications. Looking at the framing, the board's oversight mechanism is what's being described here—the ISO is just the conduit for that information flow. So this should be Board Governance.

Now I'm looking at the specific elements: ISO is a cybersecurity-specific title that counts as Firm-Specific, and the Interagency Guidelines for Safeguarding Customer Information is a named regulatory standard. For Quantifiable Verification, neither of these would count since they're both named references. The ISO title alone gives us Firm-Specific (3).

fact: ISO (Information Security Officer) — cybersecurity-specific title

fact: Interagency Guidelines for Safeguarding Customer Information — named regulatory standard

type: framework


reasoning: The paragraph's primary communicative purpose is describing the Board's oversight mechanism — the briefing cadence ('at least quarterly'), the recipient ('full Board'), and the detailed scope of topics covered in those briefings. While the CISO is the grammatical subject, the CISO serves as the delivery vehicle; the dominant content is what the Board receives and monitors. CISO is a cybersecurity-specific title on the IS list, making this Firm-Specific, but no second QV-eligible hard fact (dates, dollar amounts, named firms, named tools) is present to reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph.

The paragraph describes the CISO delivering reports to the Board. The primary actor delivering reports is the CISO, but the content is about what gets reported TO the Board - this is about Board oversight/briefing cadence.

Actually, let me reconsider. The grammatical subject is "the CISO" who "delivers a detailed report to the full Board." Per Rule 2: "CISO reports quarterly to the Board on..." → Management Role (CISO is primary actor). But wait - the bulk of the paragraph describes what topics the Board receives briefings on, which is about board oversight.

Hmm, the CISO is the grammatical subject performing the action. But the communicative purpose is really about the Board's oversight mechanism - they receive quarterly briefings on these topics.

So I'm looking at the calibration here - when the opening clause frames this as the CISO delivering reports, that's a management role framing. But Case 5 shows that if the opening clause emphasizes the Audit Committee's oversight function, it shifts to Board Governance. In this case, the opening is about the CISO's action of delivering, not the Board's oversight role, so this leans toward Management Role despite the Board being the recipient.

Actually, the dominant communicative purpose here is really about what the Board receives and how often - the briefing cadence and scope of their oversight. That's fundamentally a Board Governance concern, even though the CISO is the grammatical subject. I'll classify this as Board Governance since the paragraph's primary intent is describing the Board's information flow and oversight mechanism.

For specificity, CISO is a cybersecurity-specific title, so that's IS.

Looking at the list elements: "quarterly" is just a generic cadence, "full Board" is generic too, and there's no second QV-eligible fact here. So this qualifies as Firm-Specific (3).

fact: CISO delivers reports to the Board


specificity_confidence: medium

reasoning: The paragraph describes the company's own cybersecurity and data privacy programs, certifications achieved, and compliance frameworks — all hallmarks of Risk Management Process. It contains multiple hard verifiable facts: a specific date ('In 2025') and a verifiable certification claim ('achieved SOC2 Type 2 certification'), plus references to TX Ramp compliance and prior SOC2 Type 1 certification. The specific date plus the verifiable certification achievement (which is independently confirmable) reach the two-fact QV threshold.

thinking:
Let me analyze this paragraph.

Content: Describes the company's cybersecurity program, mentions SOC2 Type 2 certification achievement in 2025, previous SOC2 Type 1, and TX Ramp compliance. This is about internal processes and framework adoption.

Category: Risk Management Process - describes the company's own cybersecurity program, certifications, and compliance efforts.

Specificity: Let me check facts:
- "In 2025" - specific date (fiscal year)
- "SOC2 Type 2 certification" - this is a certification claim ("achieved SOC2 Type 2 certification"), which per the IS list is firm-specific (holding a certification is more than naming a standard)

- "TX Ramp compliance" - this is a named standard/program (Texas Risk and Authorization Management Program)
- "SOC2 Type 1 certification" - previous certification

Now I'm checking whether certification claims qualify as QV-eligible. The QV list includes specific dates, dollar amounts, headcounts, percentages, named third-party firms, named products/tools, and named certifications held by individuals. But certification claims like "We maintain ISO 27001 certification" appear on the IS list without explicit QV eligibility, so I need to determine if they meet the threshold.

The distinction is becoming clearer: company certifications like SOC2 Type 2 are firm-specific verifiable facts, but they're not the same as individual certifications (CISSP, CISM, CEH) that the QV list explicitly mentions. So I'm left with just the specific date "In 2025" as clearly QV-eligible, making this primarily a Firm-Specific fact.

fact: Achieved SOC2 Type 2 certification in 2025

fact: Previous SOC2 Type 1 certification

fact: TX Ramp compliance


reasoning: The paragraph describes the company's cybersecurity approach using the generic 'people, process, and technology' triad to secure environments and data, which is a high-level summary of internal risk management. It contains no named frameworks, roles, tools, dates, or any firm-specific details — entirely boilerplate language that could appear in any filing.

thinking:
Classify this paragraph.

This is a generic summary statement about "people, process, and technology" being interwoven to secure environments and data. No named frameworks, no specific facts, no named roles or tools.

Category: Risk Management Process - it's describing the company's approach to cybersecurity (people, process, technology), but very generically.

Specificity: Generic Boilerplate - no named standards, no specific facts.


reasoning: The paragraph is overwhelmingly about the people — naming Joel Austin and Malia Hodges, detailing their titles, years of experience, committee memberships, legislative testimony, and the unnamed CISO's credentials (42 years, master's and doctorate degrees). This is squarely Management Role under the person-vs-function test. Multiple QV-eligible hard facts: named individuals, specific years of experience (34, 15, 25, 6, 42), and named credentials.

thinking:
Let me analyze this paragraph carefully.

This is about management roles - it names specific individuals (Joel Austin, Malia Hodges), their titles, qualifications, experience, and backgrounds. The paragraph is primarily about WHO these people are and what makes them qualified.

Content Category: Management Role - The paragraph is about the people: Joel Austin (SVP & Chief Digital Officer), Malia Hodges (SVP & CIO), and an unnamed CISO. Their credentials, experience, backgrounds are the primary content.

Specific facts for specificity:
- Joel Austin (named individual)
- Malia Hodges (named individual)
- Senior Vice President and Chief Digital Officer (named role)

- Senior Vice President and Chief Information Officer (named role - CIO)
- CISO (named role)
- Combined decades of experience across the three leaders: 34, 25, and 42 years respectively
- 15 years of cybersecurity oversight and 6 years specifically as CIO
- Advanced credentials including a Master's degree and Doctorate in cybersecurity and information assurance
- Active involvement on the Edison Electric Institute security and technology policy committee
- Operating a 24/7/365 security team

I'm seeing multiple quantified facts here that are easily verifiable—the specific years of experience, the named roles, and the educational credentials all provide strong evidence of expertise and authority in this domain.

fact: Joel Austin, senior vice president and chief digital officer

fact: Malia Hodges, senior vice president and chief information officer

fact: Chief information security officer (unnamed)

fact: Mr. Austin has over 34 years of technology operations experience

fact: More than 15 years of cybersecurity oversight experience (Austin)

fact: Ms. Hodges has 25 years of technology operations experience

fact: Six years as chief information officer (Hodges)

fact: CISO has over 42 years of experience in cybersecurity

fact: CISO holds a master's degree in cybersecurity and a doctorate in cybersecurity/information assurance


reasoning: The paragraph's primary communicative purpose is describing management's role in cybersecurity oversight: named individuals (Mr. Austin, Ms. Hodges) and the chief risk officer establish the framework, convene quarterly meetings, assess risks, and report to the board. While it describes process mechanics (meetings, mitigation strategies, information distribution), the management actors are the grammatical subjects throughout, and the reporting-to-board structure places this as Management Role per Rule 2 ('Management role reports TO the board → Management Role'). Named individuals make this Firm-Specific; no QV-eligible facts (dates, dollar amounts, named firms/tools, certifications) reach the two-fact threshold.

thinking:
Let me analyze this paragraph.

Content: Describes a risk management framework established by senior leadership, including named individuals (Mr. Austin, Ms. Hodges), chief risk officer, quarterly meetings to assess risks including cybersecurity, and reporting to the Audit Committee and board.

Category: This is a mixed paragraph. It describes management's risk management framework and reporting to the board. The primary actors are the senior leadership team, chief risk officer, and named individuals. The paragraph describes both the process (risk management framework, meetings, mitigation strategies) and the reporting structure to the board.

The dominant theme is the risk management framework and how it operates, with reporting to the board as the output.

Now I'm thinking through whether this is really about the people or the process itself. The grammatical subjects are the senior leadership team and chief risk officer, but the paragraph is fundamentally describing the risk management framework and its operations—the meetings, assessments, and reporting structure—rather than the individuals' qualifications or backgrounds. Even without the names, the core content about how the framework functions remains intact. the paragraph is fundamentally about what management does in overseeing risk—they establish the framework, run quarterly meetings with the chief risk officer, discuss assessments and mitigation strategies, and report findings to the board. The named individuals and their specific actions anchor this as Management Role rather than an abstract process description. I'm going back and forth on the right category here. The paragraph does focus on management's role—Mr. Austin and Ms. Hodges as named individuals, the chief risk officer position, their quarterly meetings, and how they report findings to the board. These are firm-specific details about who's responsible for what. That makes Management Role the better fit than Risk Management Process, since the structure really centers on the management actors and their responsibilities rather than just describing a generic framework.

fact: Mr. Austin (named individual in senior leadership)

fact: Ms. Hodges (named individual in senior leadership)

fact: Chief risk officer role


reasoning: The paragraph describes the company's own internal audit processes for cybersecurity, which is a risk management activity. It contains no named frameworks, specific roles, dates, or any other facts from the IS list — 'regularly' is a generic cadence and 'internal audits' is a common practice.

thinking:
Classify this paragraph.

Content: describes internal audits of processes and controls relating to cybersecurity. This is about the company's own internal processes.

Category: Risk Management Process

Specificity: No named frameworks, no specific facts from the IS list. "regularly perform internal audits" is generic. → Generic Boilerplate


content_category: Strategy Integration

reasoning: The paragraph references a past incident but its primary communicative purpose is the financial impact ($14.3M costs) and the materiality conclusion ('no material impact to our financial results'). Per the tiebreaker, a brief mention of a past incident plus a materiality/cost conclusion as the main point maps to Strategy Integration. Two or more QV-eligible hard facts (specific date July 23, 2023 + $14.3M dollar amount) yield Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes a past cybersecurity incident with specific details about what happened, when, costs, and the conclusion. Let me break it down:

1. It references a specific incident on July 23, 2023
2. It mentions $14.3 million in costs
3. It includes a materiality assessment ("no material impact")

Category decision: This paragraph describes an actual incident (date, what was affected, response) AND discusses financial impact ($14.3M costs) AND makes a materiality assessment.

The tiebreaker says: "Paragraph DESCRIBES what happened in an incident (dates, access, encryption, scope, response actions) → Incident Disclosure" but also "Paragraph ONLY discusses financial cost, insurance, or materiality of an incident WITHOUT describing the event → Strategy Integration."

The incident description is brief—just the date and affected systems—while the bulk of the content focuses on financial costs and the materiality conclusion. This leans toward Strategy Integration since the financial and materiality aspects dominate the paragraph's purpose. go with Strategy Integration because the paragraph's dominant purpose is establishing the financial materiality of the incident, even though it includes some incident context.

Looking at the specificity markers: there's a concrete date of July 23, 2023 and a dollar amount of $14.3 million, plus the year-end reference and mention of forensic investigation—all of which qualify as quantified-verifiable facts.

fact: July 23, 2023 incident date

fact: $14.3 million in costs

fact: year ended 2023


reasoning: The paragraph describes how cybersecurity is integrated into the company's enterprise risk management through a named internal function (GRC). This is about internal processes/ERM integration, making it Risk Management Process. The named 'Governance, Risk, and Compliance (GRC) function' with its specific abbreviation qualifies as a named internal program with a unique identifier, pushing it to Firm-Specific.


reasoning: The paragraph describes the company's own internal policies (information security, access management) designed to protect IT assets, with a third-party specialist mentioned as one component of internal processes rather than as the central topic. No named frameworks, roles, firms, dates, or other specific facts are present — 'third-party specialist' is an unnamed entity on the NOT list.

thinking:
Let me classify this paragraph.

Content: Describes internal policies (information security, access on/offboarding, access and account management) and mentions consulting a third-party specialist for cyber risk management.

Category: This is about the company's own internal processes - policies governing IT protection. The third-party mention is a component of their internal program, not the central topic. → Risk Management Process

Specificity: Let me check for specific facts:
- "information security, access on/offboarding, and access and account management" - these are generic policy areas
- "third-party specialist" - unnamed entity → NOT list
- No frameworks, no named roles, no dates, no numbers

- This reads as generic boilerplate without concrete details.


reasoning: The paragraph's primary communicative purpose is describing the company's generic approach to cybersecurity risk management — proactive detection, investigation, prevention, and updating internal processes/tools. While it opens with hypothetical risk language and ends with a cross-reference, the central content is a (very generic) process description. It does not make an explicit materiality assessment ('have not materially affected our business strategy'), so it does not qualify as Strategy Integration; 'could have a material adverse effect' is hypothetical risk language, not a materiality conclusion. No named frameworks, roles, tools, dates, or firm-specific facts are present.

thinking:
Let me analyze this paragraph.

Content: Mix of generic risk language, a materiality-adjacent statement, mention of no incidents, description of generic detection/prevention activities, and a cross-reference to Risk Factors.

The paragraph opens with generic risk language about cybersecurity threats having material adverse effect. It acknowledges cyber risk is prevalent. States "To date, we have not had a cybersecurity incident" - this is a materiality-type assessment. Then describes generic proactive detection/prevention. Then mentions regulatory compliance concerns. Ends with cross-reference.

Category: The dominant purpose is generic risk language. There's a materiality-adjacent statement ("could have a material adverse effect") but it's not a direct materiality assessment like "have not materially affected our business strategy." The statement "To date, we have not had a cybersecurity incident" is closer to incident disclosure (absence of incidents) but also feeds into strategy integration.

The "could have a material adverse effect" language is purely hypothetical risk framing rather than an actual materiality conclusion. The no-incidents statement is factual disclosure but doesn't constitute a materiality assessment. The middle section describing detection and prevention activities is generic risk management process language, and the paragraph lacks any explicit statement about whether cyber issues have actually materially impacted the business strategy. describing its approach to managing cyber risk, even if generically. There are no named frameworks, specific roles, dates, or concrete facts from any incident summary list—it's all standard boilerplate language. That confirms Generic Boilerplate as the specificity level.


reasoning: The paragraph primarily describes the company's internal processes for assessing, identifying, preventing, and managing cybersecurity risks, with ERM integration. Third-party service providers are mentioned as a component of the internal program (not the central topic), and the Board/Audit Committee oversight is a brief subordinate clause. No named frameworks, cybersecurity-specific roles, dates, or other IS-list facts are present—'Audit Committee' and 'Board' are on the NOT list, and third parties are unnamed.

thinking:
Let me analyze this paragraph.

Content: Describes processes for managing cybersecurity risks, mentions third-party service providers, ERM integration, and board/Audit Committee oversight.

Category: The paragraph describes the company's internal processes (assessing, identifying, preventing, managing risks), mentions third parties as a component, and notes ERM integration. The board/Audit Committee mention is brief. The dominant topic is the company's risk management processes. → Risk Management Process

Specificity: Let me check facts:
- "Audit Committee" — on the NOT list (generic governance)
- "Board" — on the NOT list
- "third party service providers" — unnamed, on NOT list

- No named frameworks, no named roles, no dates, no numbers, no IS-list facts, no named standards → Generic Boilerplate


reasoning: The paragraph describes the company's own internal processes and systems designed to assess, identify, and manage cybersecurity risks — squarely Risk Management Process. It contains no named frameworks, no specific roles, no dates, no tools, and no firm-specific details; the language is entirely generic and could appear in any company's filing unchanged.

thinking:
Classify this paragraph.

This describes internal processes and systems for managing cybersecurity risks. No named frameworks, no specific roles, no dates, no firm-specific details.

Category: Risk Management Process - describes internal processes for assessing/managing cyber risks.

Specificity: Generic Boilerplate - completely generic language, no named standards, no firm-specific facts.


reasoning: This is a SPAC with no business operations that explicitly states it has no cybersecurity risk management program or formal processes. Per the codebook's SPAC rule, the absence of a program is not a program description, and the perfunctory board mention ('generally responsible... if there is any') is not substantive governance disclosure. None/Other with Specificity 1.

thinking: SPAC/no-operations company, explicitly no program.


reasoning: The paragraph covers multiple topics but the dominant framing is the Audit Committee's oversight role and the management reporting structure into it (sentences 3-4). The CFO's cybersecurity responsibility is described as reporting to the Audit Committee, making the board committee the primary oversight actor per Rule 2. No IS-list facts remain after filtering: 'Audit Committee' and 'CFO' are both on the NOT list, 'cyber security insurance company' is unnamed, and '2023' is simply the reporting period rather than a specific event date.

thinking:
Let me analyze this paragraph carefully.

Content: This paragraph covers multiple topics:
1. No cyber incidents (materiality/incident statement)
2. Risk management follows insurance company guidelines
3. Audit Committee oversight
4. CFO responsible for cybersecurity management

Let me determine the dominant category. The paragraph touches Board Governance (Audit Committee oversight), Management Role (CFO responsibility), Risk Management Process (follows guidelines), and Strategy Integration (no incidents).

Looking at the structure: The paragraph is really a compressed overview touching multiple areas. Let me assess dominance:
- Sentence 1: No incidents experienced - this is a materiality-adjacent statement

- Sentence 2: Risk management follows insurance company guidelines - Risk Management Process
- Sentence 3: Audit Committee oversight - Board Governance
- Sentence 4: CFO's role and reporting to Audit Committee - Management Role / Board Governance

This is a tough call. The paragraph doesn't have a single dominant theme - it's a compressed disclosure covering governance, management, and process. The Audit Committee and CFO reporting structure take up about half the paragraph. The CFO is the grammatical subject in the last sentence, but the Audit Committee is prominent too.

Looking at Rule 2: "Management role reports TO the board" → Management Role. The CFO "reports and coordinates any potential material risk to the Audit Committee" - this fits the pattern of management reporting to board oversight. That's the dominant categorization here.

Actually, let me reconsider. The paragraph has roughly equal weight across topics. The last two sentences focus on governance structure - Audit Committee oversight plus CFO reporting to Audit Committee. The board/committee is given oversight responsibility, and the CFO reports to it. Sentence 3 makes the Audit Committee the subject. Sentence 4 makes management/CFO the subject reporting to the Audit Committee.

I think Risk Management Process could work since the paragraph describes the overall approach - following insurance guidelines, committee oversight, management assessment. But the dominant theme seems to be the governance/oversight structure.

Given Rule 2: "Board delegates responsibility to management" → Board Governance. The Audit Committee has oversight, and the CFO reports to it. This feels like the core message - the governance framework where the board's committee oversees management's risk assessment and reporting.

Specificity check: "Audit Committee" is on the NOT list as generic, so I need to be careful there.

The dominant content is really the governance structure in sentences 3-4, so I'm going with Board Governance as the category.

Looking at the specificity requirements, there are no IS-list facts here - no named committees beyond the Audit Committee, no named frameworks, no specific event dates, no named firms, and no numbers. The "cyber security insurance company" is mentioned but unnamed, so it doesn't count as a specific firm. "2023" is just the fiscal year being reported, not a specific event date.

This is generic boilerplate content about board governance and Audit Committee oversight, with the CFO providing standard reporting.


reasoning: This paragraph is a cross-reference directing readers to Item 1A Risk Factors with no substantive cybersecurity disclosure content — no materiality assessment, no description of processes, governance, or incidents. Pure cross-reference → None/Other.


reasoning: The paragraph describes the company's internal information security processes for identifying, assessing, and managing cybersecurity risks to its systems and data. This is squarely Risk Management Process. No named frameworks, no cybersecurity-specific roles, no firm-specific facts — the language is generic and could apply to any company. Mentions of 'clinical trial data' and 'intellectual property' describe the scope of protected data but are not specific facts per the IS list.

thinking:
Classify this paragraph.

Content: Describes maintaining information security processes to identify, assess, and manage cybersecurity risks. This is about internal processes/risk management.

Category: Risk Management Process - describes risk assessment methodology and what the program covers.

Specificity: No named frameworks, no firm-specific facts. Mentions "clinical trial data" which hints at the company's nature but isn't a specific fact per the IS list. Everything here is generic boilerplate language.

Generic Boilerplate.


reasoning: The paragraph describes the company's cybersecurity risk management program and its alignment with industry standards, which is squarely Risk Management Process. However, it names no specific framework (just 'industry standards'), no specific tools, roles, or firm-specific details, making it Generic Boilerplate.


reasoning: The paragraph's primary subjects are the Audit Committee and Board of Directors overseeing cybersecurity risk, including briefing cadence and scope of oversight. No firm-specific facts appear: 'Audit Committee' and 'Board of Directors' are generic governance terms, cadences are vague ('at least annually'), and third-party consultants are unnamed.

thinking:
Let me analyze this paragraph.

Content: The Audit Committee reviews internal controls and cybersecurity. Cybersecurity stakeholders brief the Audit Committee. Board reviews cybersecurity risks annually.

Category: The grammatical subjects are the Audit Committee and the Board. This is about board/committee oversight. → Board Governance

Specificity: Let me check for specific facts.
- "Audit Committee" — on the NOT list (generic governance)
- "Board of Directors" — on the NOT list
- "member(s) of management" — generic
- "third-party consultants" — unnamed, on NOT list
- "at least an annual basis" — generic cadence

- "at least annually" — also generic cadence

There are no named frameworks, no firm-specific facts, no cybersecurity-specific titles beyond the generic management assignment, and no named committees beyond the Audit Committee. This is generic boilerplate.


reasoning: The paragraph describes how cybersecurity risk assessment is integrated into the company's overall ERM process, with the Information Security Management committee evaluating risks and reporting upward. The audit committee mention is subordinate context for the reporting line, not the primary topic. The named 'Information Security Management committee' is a non-generic committee unique to this company, triggering Firm-Specific. Notable that the language is aspirational/future-tense ('will be integrated'), but the category and specificity are assessed on content regardless.

thinking:
Let me analyze this paragraph.

Content: Describes integration of cybersecurity into ERM, mentions an "Information Security Management committee" that evaluates risks and reports to the audit committee.

Category: This is about risk management processes - ERM integration, how cybersecurity risk assessment works. The audit committee mention is subordinate. The primary topic is how the company manages/assesses cyber risks. → Risk Management Process

Specificity:
- "Information Security Management committee" — this is a named non-generic committee → Firm-Specific fact
- "audit committee" — generic, on the NOT list
- "will be integrated" — future tense, notable but doesn't change classification

- No named frameworks, dates, dollar amounts, or other firms mentioned, so just the one committee name qualifies as firm-specific.


reasoning: The paragraph frames cybersecurity as critical to achieving strategic business objectives and protecting intellectual property, notes hypothetical material adverse effects ('could materially adversely affect our operations, performance and results of operations'), and states the company is investing in cyber defense systems and training programs. The dominant communicative purpose is strategic framing of cybersecurity's importance and the company's investment response, placing it in Strategy Integration. No named frameworks, cybersecurity-specific roles, dates, tools, or other facts from the IS list are present — threat types like 'ransomware' and 'nation state actors' and business descriptors like 'quantum photonic products' are generic context, not firm-specific cybersecurity disclosure.

thinking:
Let me analyze this paragraph.

Content: This paragraph discusses cybersecurity threats the company faces, mentions customers/suppliers face similar threats, and states they're investing in cyber defense. It includes a materiality-adjacent statement ("could materially adversely affect") but this is hypothetical risk language, not a materiality assessment conclusion. It's general business language about why cybersecurity matters.

Category: This is mostly generic risk language. There's a brief mention of "could materially adversely affect our operations, performance and results of operations" but this is hypothetical ("could"), not an explicit materiality assessment ("have not materially affected" or "are not reasonably likely to materially affect").

The paragraph outlines threat types like ransomware and nation-state actors, notes that customers and suppliers face similar risks, and mentions they're evaluating best practices and investing in defense systems and training—but it doesn't detail actual governance structures, board oversight mechanisms, or specific management responsibilities for cybersecurity oversight. The language about evaluating best practices and investing in defense systems points toward Risk Management Process, but the real focus here is the strategic importance of cybersecurity to their business and how they're responding to threats—that's Strategy Integration. Looking at the specificity though, there are no named frameworks, firm-specific cybersecurity facts, roles, committees, tools, dates, or amounts. The threat descriptions like ransomware and nation-state actors are generic, and while quantum computing describes their business context, it's not a cybersecurity-specific detail from the IS list. This reads as Generic Boilerplate.


reasoning: The paragraph opens with 'Our approach includes...' framing it as a description of the company's cybersecurity processes (regular updates, intelligence sources, security tools). The consultant's 30-year experience is supporting credibility detail subordinate to the process description. While the qualifications resemble Management Role content, the consultant is an unnamed third party filling a process function, and the paragraph's primary communicative purpose is describing the company's security approach. One QV-eligible fact (30 years of experience) reaches Firm-Specific but not Quantified-Verifiable, which requires two hard facts.

thinking:
Let me analyze this paragraph.

Content: Describes a third-party security consultant's role and qualifications (30 years experience, cybersecurity expertise areas).

Category: This is about a person's qualifications - the third-party security expert consultant. It describes their experience and background. But this is a third-party consultant, not an internal management role. However, the paragraph describes what the company does (regular updates, leveraging intelligence, using tools) AND the consultant's qualifications.

The person-vs-function test: The first sentence describes processes (updates, intelligence, tools) - that's Risk Management Process. The second sentence describes the consultant's qualifications (30 years experience, areas of expertise) - that's more like Management Role but for an external party.

I'm reconsidering whether a third-party consultant functioning in this capacity could qualify as a management role under SEC rules, but the paragraph's primary focus is really on the company's security approach—the processes and tools they use—with the consultant serving as a supporting element rather than the main subject. This leans toward Risk Management Process. The paragraph blends process and management elements roughly equally, but since it frames everything as "our approach," I'm categorizing it as Risk Management Process with the consultant's credentials as supporting detail. For specificity, I've got one concrete fact—over 30 years of experience—which qualifies as QV-eligible, but that's only one hard data point when I need two for the Firm-Specific classification. The rest is vague: unnamed consultant, generic "advanced security tools," no named frameworks or vendors.

fact: Third-party security expert consultant has over 30 years of experience


specificity_confidence: low

reasoning: The paragraph describes the company's own internal cybersecurity approach ('risk-based approach,' 'cybersecurity policies throughout our operations'), making it Risk Management Process. The language is entirely generic boilerplate except for the parenthetical '(Amazon Web Services),' which appears to be a PDF extraction artifact rather than a meaningful disclosure about AWS usage. Technically the named firm triggers Firm-Specific, but confidence is low because the mention lacks any contextual integration into the sentence and is almost certainly noise from document parsing.

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

Content: "We take a risk-based approach to cybersecurity and have implemented cybersecurity policies throughout our operations that are designed to address cybersecurity threats and incidents. (Amazon Web Services)"

This describes the company's own internal cybersecurity approach - risk-based, policies throughout operations. The "(Amazon Web Services)" at the end appears to be an erroneous extraction artifact or parenthetical mention.

Category: Risk Management Process - describes internal cybersecurity approach and policies.

Specificity: The mention of "Amazon Web Services" in parentheses is odd - it could be a named system/tool/platform. But it seems like an extraction artifact rather than a substantive disclosure about AWS being part of their program. The rest is completely generic boilerplate language.

The parenthetical reference to Amazon Web Services is technically present in the text, though it's disconnected from the sentence and likely pulled from an unrelated element during extraction. Even if it's an artifact, I should note what's actually there while acknowledging the lack of meaningful context around it.

fact: Amazon Web Services (appears as parenthetical — likely an extraction artifact rather than substantive disclosure)


reasoning: The paragraph contains generic forward-looking disclaimer language about cyber risks evolving, a vague commitment to continue updating measures, and a cross-reference to Item 1A Risk Factors. There is no substantive cybersecurity disclosure — no processes, governance details, materiality assessment, or incident description. It makes no explicit materiality conclusion ('materially affected'), so it does not qualify as Strategy Integration.

thinking:
Let me analyze this paragraph.

Content: Forward-looking disclaimer about cyber risks, generic statement about evolving threats, and a cross-reference to Risk Factors. No substantive disclosure - no processes, no governance, no incident, no materiality assessment.

Category: None/Other - this is generic risk language plus a cross-reference. No materiality assessment ("materially affected" language is absent).

Specificity: Generic Boilerplate - no specific facts.


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

thinking: SPAC, no operations, no program.


reasoning: The paragraph lists cybersecurity activities (risk identification, monitoring, mitigation, remediation, program maintenance) attributed to the MIS supervisor. Applying the person-vs-function test, removing the role attribution leaves a complete process description — no credentials, background, or reporting lines are provided, so this is about the function, not the person. 'MIS supervisor' is a generic IT management title not on the cybersecurity-specific IS list (comparable to 'IT Manager' on the NOT list), so no firm-specific fact is present.

thinking:
Classify this paragraph.

The paragraph describes what the "MIS supervisor" does - identifying/assessing risks, monitoring, mitigation, maintaining programs. This is about both who is responsible (a role) and what processes they oversee.

Applying the person-vs-function test: If I remove "MIS supervisor," the paragraph describes processes - identifying risks, monitoring, mitigation, remediation, maintaining programs. It's about the function. But the paragraph's primary subject IS the MIS supervisor and what they're responsible for.

Actually, let me re-read. "MIS supervisor is responsible for identifying and assessing cybersecurity risks..." - this is describing what the role does, not the person's credentials/background.

The core content here is really about the processes themselves - risk assessment, monitoring, mitigation, remediation, maintaining programs - with the MIS supervisor serving as the attribution. Stripping away the role holder leaves substantive process description intact, which points toward Risk Management Process classification. Though I keep hesitating because the paragraph is structured around the supervisor's responsibilities, the codebook's test suggests the function is what matters here.

Now I'm checking whether "MIS supervisor" qualifies as a cybersecurity-specific title. It's not on the IS list - that includes CISO, CTO, CIO, and similar roles - so it's more of a generic IT designation. That distinction might matter for how I classify this.


reasoning: The paragraph opens with the Board of Directors' oversight responsibility for cybersecurity and frames the CFO's role as subordinate to board oversight (reporting to the board, updating the board). Board is the primary actor and framing subject. No IS-list facts are present: CFO is generic C-suite (NOT list), 'quarterly' is a generic cadence, 'Board of Directors' and 'incident response plan' are both on the NOT list. No named frameworks, cybersecurity-specific titles, or firm-specific details.

thinking:
Let me analyze this paragraph.

Content: Board oversight of cybersecurity, CFO responsible for cyber risk, quarterly updates to board, incident response notification.

Category: Mixed - Board oversight + management role (CFO). The board is the subject of the first few sentences, but CFO is also prominent. Let me check the dominant category.

Sentences:
1. "Our Board of Directors has specific oversight responsibility for cybersecurity" - Board Governance
2. "The Board of Directors reviews and discusses with management..." - Board Governance
3. "Our chief financial officer has primary responsibility for assessing, monitoring and managing cybersecurity risks." - Management Role

4. "Our chief financial officer provides an update to the Board of Directors on any risks related to cybersecurity on a quarterly basis." - The CFO is the primary actor here, even though they're reporting to the board, so this counts as Management Role.

Looking at the distribution, I have two sentences clearly about board governance, two about the CFO's management responsibilities, and one about incident response procedures. The paragraph seems to be split between board oversight and management roles, but the CFO's responsibilities take up a significant portion. I need to determine if this leans more toward Management Role or stays Mixed.

Actually, the opening really does frame this around board oversight - the CFO's quarterly reporting is presented as part of the board's governance structure. The CFO is the mechanism through which the board gets its information. So this is Board Governance.

For specificity, I'm checking: "Board of Directors" is generic governance, "chief financial officer" is generic C-suite, "quarterly" is just a cadence, and "incident response plan" is a generic program name. No named frameworks, no IS-list items, and CFO is on the NOT list as generic C-suite. No cybersecurity-specific titles either.

This falls under Generic Boilerplate.


reasoning: The paragraph describes internal cybersecurity processes — designing safeguards, monitoring effectiveness, incident notification plans, and resource allocation. The CFO designation at the end is an incidental attribution; CFO is generic C-suite (on the NOT list) and the paragraph's substance is about processes, not the person. No named frameworks, tools, dates, or firm-specific facts remain after filtering.

thinking:
Let me analyze this paragraph.

Content: Describes safeguards, monitoring, processes for notifying stakeholders, and designates the CFO for cybersecurity risk management.

Category: This is primarily about internal processes - designing safeguards, monitoring, incident communication plans. The CFO mention at the end is an attribution. The paragraph is about what the company does (processes), not about who the person is. → Risk Management Process

Wait - CFO is on the "IS NOT" list as generic C-suite. Let me check... "Generic C-suite: CEO, CFO, COO, President, General Counsel — these exist at every company and are not cybersecurity-specific."

So the CFO designation doesn't add specificity here. Looking at the rest of the content, there are no named frameworks, specific dates, named tools, or firm-specific facts that would elevate this beyond generic boilerplate language.


reasoning: This paragraph is a cross-reference directing the reader to Item 1A Risk Factors for cybersecurity risk descriptions. The phrase 'may materially affect us' is not a materiality assessment/conclusion (e.g., 'have not materially affected our business strategy, results of operations, or financial condition') — it is generic framing language introducing the cross-reference. The quoted risk factor titles are boilerplate risk language, not substantive cybersecurity disclosure. Per the codebook, a cross-reference without an explicit materiality conclusion is None/Other.

thinking:
Cross-reference to Risk Factors with quoted risk factor titles, but no materiality assessment conclusion. Let me check - does it say "may materially affect us"? Yes: "risks from cybersecurity threats that may materially affect us and how they may do so." That's a materiality framing but it's pointing to risk factors, not making a conclusion.

Wait - "risks from cybersecurity threats that may materially affect us" - this is acknowledging that cybersecurity threats may materially affect the company, then directing to Item 1A. It's not a materiality *assessment* (like "have not materially affected"), it's a cross-reference with a generic framing. Per the codebook, a pure cross-reference is None/Other. The phrase "may materially affect" is not a conclusion - it's just saying "for risks that may affect us, see Item 1A."

This is just a cross-reference to the risk factors section without any actual materiality conclusion about whether these risks have or haven't affected the business. So that's None/Other, Specificity 1.


reasoning: The paragraph describes management's responsibility for cybersecurity risk and identifies the CEO as overseeing the IT department for cyber incident monitoring. The CEO is the grammatical subject performing the oversight action, making this Management Role. However, CEO is a generic C-suite title (on the NOT list), 'information technology department' is generic, and no cybersecurity-specific roles, frameworks, or firm-specific facts are present, resulting in Generic Boilerplate.

thinking:
Let me analyze this paragraph.

The paragraph has two sentences:
1. "Management is responsible for identifying and assessing material risks for the business on an ongoing basis, including in relation to cybersecurity." - Generic management responsibility statement.
2. "Our Chief Executive Officer oversees our information technology department which monitors the prevention, detection, mitigation, and remediation of cyber incidents, if any." - CEO oversees IT department for cyber.

Category: The paragraph describes management's role in cybersecurity. The CEO is the grammatical subject of the second sentence. But CEO is on the NOT list (generic C-suite). The paragraph is about management's responsibility and the CEO overseeing IT. There's no cybersecurity-specific role (CISO, CIO, CTO). The CEO is generic C-suite.

This falls under Management Role since it's describing how the CEO handles cybersecurity oversight through the IT department, but since the CEO is a generic C-suite position and there's no specific cybersecurity leadership mentioned, this reads as Generic Boilerplate.


reasoning: The paragraph contains an explicit materiality assessment ('have to date not materially affected... our business strategy, results of operations or financial condition'), which per Rule 6 makes it Strategy Integration regardless of the appended cross-reference to Risk Factors. No named frameworks, firm-specific facts, or verifiable details are present — this is boilerplate materiality language found across thousands of filings.

thinking:
Materiality assessment present → Strategy Integration per Rule 6.

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


reasoning: The paragraph describes the company's internal cyber risk management program and its integration with ERM, which is squarely Risk Management Process. It contains no named frameworks, roles, tools, or firm-specific details — entirely generic language that could apply to any company.


reasoning: The Audit Committee is the grammatical subject receiving incident updates and reports, making this Board Governance. Two QV-eligible hard facts: a specific date (2024) and a specific count (one report), plus a cybersecurity-specific role title.

thinking:
Let me analyze this paragraph.

The paragraph discusses the Audit Committee receiving updates about cybersecurity incidents from management, and notes a specific report from the Senior Director of Cybersecurity and Compliance in 2024.

Category: The Audit Committee is the subject receiving reports - this is about board-level oversight. Board Governance.

Specific facts:
- "Senior Director of Cybersecurity and Compliance" - cybersecurity-specific title → IS list
- "2024" - specific date (fiscal year) → IS list
- "one report" - a specific number/quantified fact

QV check: "2024" (specific date), "one report" (quantified), "Senior Director of Cybersecurity and Compliance" (named role - but named roles don't count toward QV). So date + quantified = 2 QV-eligible facts → Quantified-Verifiable.

fact: 2024 (specific fiscal year)

fact: one report received


reasoning: The paragraph's grammatical subjects are the CEO and CFO, and the entire sentence is framed around how they supervise cybersecurity efforts — making management's supervisory role the primary communicative purpose. However, the person-vs-function test is borderline: the paragraph describes processes (briefings, threat intel, security tools) as means of supervision rather than the individuals' credentials or backgrounds. CEO and CFO are generic C-suite titles (on the NOT list), no named frameworks, tools, firms, or dates appear, and all other references ('internal security personnel,' 'external consultants,' 'security tools') are unnamed and generic, yielding Generic Boilerplate.

thinking:
Let me classify this paragraph.

Content: CEO and CFO supervise cybersecurity efforts through briefings, threat intelligence, and security tools.

Category: The grammatical subjects are CEO and CFO. But CEO and CFO are generic C-suite titles (on the NOT list). The paragraph describes what they do to manage cyber risk - briefings, threat intelligence, alerts. This is about management's role in cybersecurity oversight, but CEO/CFO are generic titles. The content describes processes (briefings, threat intelligence, security tools) but framed through management supervision.

Person vs function test: This is about what CEO/CFO do (supervise efforts), not about who they are (credentials, background).

Looking at this more carefully, the paragraph frames management roles as the subject but really focuses on the processes they oversee—briefings, threat intelligence, security tools. This fits Rule 2b: when a role title is mentioned as attribution followed by process description, it's a Risk Management Process. The CEO and CFO are just the attribution here; the actual content is about the oversight processes themselves. I should remove the generic titles and focus on the processes being described. The paragraph lacks any specific details—CEO and CFO are too generic, and terms like "internal security personnel" and "security tools" are vague placeholders without naming actual frameworks or concrete examples. This is clearly Generic Boilerplate at Specificity level 1.


reasoning: The paragraph describes the company's internal information security program, listing policy domains (access control, endpoint protection, incident response, etc.) and a risk register — all internal cybersecurity processes. No named frameworks, cybersecurity-specific roles, named tools, dates, or other facts from the IS list are present; the listed domains are common practices and 'Risk Register' is a generic program name.

thinking:
Let me analyze this paragraph.

Content: Describes the company's information security program - policies, procedures covering various domains, and a risk register. This is about internal processes.

Category: Risk Management Process - describes the company's own internal cybersecurity processes, policies, and risk assessment methodology.

Specificity: Let me check for specific facts.
- Lists generic security domains (access control, endpoint protection, etc.) - these are common practices, not specific
- "Risk Register" - this is a generic program name, not a unique identifier
- No named frameworks (NIST, ISO, etc.)
- No named roles, tools, firms, dates, numbers

- No cybersecurity-specific titles

After filtering through the IS/NOT lists, nothing concrete emerges - just standard security terminology without any distinguishing details or named standards.

→ Generic Boilerplate (1)


reasoning: This paragraph defines the scope of the company's cybersecurity risk management program, covering Confidential Information, Critical Systems, and service providers. It is framing/scoping language for the risk management program description that follows, making Risk Management Process the best fit. No named frameworks, specific roles, dates, or firm-specific facts are present — the defined terms are generic internal labels, not unique identifiers.


content_category: Third-Party Risk

reasoning: The paragraph's central topic is oversight of external parties — it describes which types of third-party providers the company uses and how it manages cybersecurity risks associated with them ('reviewing their security assessments and applicable reports'). All providers are unnamed ('cybersecurity software providers,' 'managed cybersecurity service providers,' 'penetration testing firms'), no frameworks or standards are cited, and no firm-specific facts appear, yielding Generic Boilerplate.

thinking:
Let me analyze this paragraph.

Content: Describes use of third-party service providers for cybersecurity and general business functions, and how the company manages risks from these providers.

Category: The central topic is oversight of third-party providers - both cybersecurity vendors and general business vendors. The paragraph describes requirements/processes imposed on/related to external parties. This is Third-Party Risk.

Specificity: Let me check for specific facts:
- No named firms, tools, dates, dollar amounts, headcounts
- No named frameworks (NIST, ISO, etc.)
- Generic descriptions: "cybersecurity software providers", "managed cybersecurity service providers", "penetration testing firms", "application providers", "hosting companies" - all unnamed

- The mention of reviewing security assessments and reports is also vague and lacks concrete detail.

This is Generic Boilerplate.


reasoning: The paragraph describes a specific cybersecurity incident — a business email compromise (BEC) attack in 2023 where a threat actor impersonated Sphere 3D's CFO and redirected 26 BTC (~$560,000) to a fraudulent wallet. It includes multiple hard verifiable facts: a specific date (2023), named third-party firm (Sphere 3D Corp.), dollar amount (~$560,000), quantified loss (26 BTC), and named entity (Gryphon), well exceeding the two-fact QV threshold.

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

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

fact: Sphere 3D Corp.

fact: 26 BTC transferred

fact: approximately $560,000

fact: Gryphon engaged with US Federal law enforcement


reasoning: The paragraph describes remediation actions following a cybersecurity incident — wiring funds to make Sphere 3D whole for stolen BTC, engaging a forensic firm, findings about the attack vector, and control modifications. While the $560,000 payment is a financial detail, it is embedded within the incident narrative describing response actions and outcomes, making Incident Disclosure the dominant category. Three hard verifiable facts (specific date, dollar amount, named firm Sphere 3D) meet the QV threshold.

thinking:
Let me analyze this paragraph carefully.

This describes the aftermath/response to a cybersecurity incident - Gryphon wired USD to Sphere 3D for stolen BTC, engaged a forensic firm, found the threat actor didn't enter via Gryphon's systems, modified controls, and made a $560,000 payment.

This is describing what happened in response to an incident - remediation actions, forensic investigation results, and financial impact.

Category: This is primarily about incident response and remediation. It describes actions taken after an incident (wiring money, forensic analysis, control modifications, payment). The $560,000 payment is a financial detail but it's part of the incident narrative/response. The dominant content is incident description/response. → Incident Disclosure

I'm checking what concrete details are present here - there's a specific quarter date, a dollar amount, and a named firm involved, which gives me at least three verifiable facts to work with. → Quantified-Verifiable

fact: quarter ended June 30, 2023

fact: $560,000 payment to Sphere 3D

fact: Sphere 3D (named third party)


reasoning: The paragraph describes how some 'coverage' (likely insurance or a third-party service referenced in a preceding paragraph) supports the company's risk management efforts to 'identify, mitigate, and respond to potential threats.' The substantive content is about bolstering internal risk management capabilities, making Risk Management Process the best fit, though without the preceding paragraph the referent of 'this coverage' is ambiguous. No named frameworks, roles, dates, tools, or any firm-specific facts are present — entirely generic language that could appear in any filing.

thinking:
Classifying this paragraph from La Rosa Holdings Corp.'s 10-K Item 1C.

The paragraph says "This coverage supports our risk management efforts by providing additional resources and expertise to help us identify, mitigate, and respond to potential threats effectively."

This refers to some "coverage" (likely insurance or a third-party service mentioned in a prior paragraph) supporting risk management. Without more context, "coverage" likely refers to cybersecurity insurance or a service.

Content category: This is generic language about coverage supporting risk management. It mentions "identify, mitigate, and respond to potential threats" which is generic risk management language. But "coverage" suggests insurance → Strategy Integration? Or could be third-party service coverage.

The word "coverage" in SEC filings typically points to insurance, though it could also mean monitoring or service coverage. The description of "additional resources and expertise" for identifying and mitigating threats leans toward either insurance coverage or third-party risk management services, making this either Strategy Integration or Third-Party Risk depending on what the preceding context reveals. The paragraph is fundamentally about how external support bolsters the company's risk management capabilities—specifically its ability to identify, mitigate, and respond to threats. That's the core of what's being described, so Risk Management Process is the right classification. As for specificity, there's nothing concrete here—no named frameworks, no actual details about what's being covered or how. It's pure boilerplate.


reasoning: This is a SPAC with no business operations that explicitly states it has no cybersecurity program or formal processes. Per the codebook's SPAC rule, the absence of a program is not a description of a program, and the perfunctory board mention ('generally responsible... if any') is not substantive governance disclosure.

thinking: SPAC/no-operations company.


reasoning: The paragraph describes the IT team's qualifications, experience, alignment with executive leadership, and augmentation through an outsourced provider offering virtual CISO services — all centered on who manages cybersecurity and their credentials, making it Management Role. Specificity is Firm-Specific: the mention of virtual CISO services (a cybersecurity-specific role from the IS list) and specific experience figures are firm-specific facts, but they do not reach Quantified-Verifiable because '25 years of collective experience' is a soft team-aggregate figure and '23 years of operation' refers to an unnamed provider, making neither independently verifiable in the QV sense.

thinking:
Let me analyze this paragraph.

Content: Describes the IT team's experience, their alignment with CEO/leadership, and a partnership with an outsourced IT provider offering virtual CTO/CISO services.

Category: This is about the people/team responsible for cybersecurity management. It describes qualifications (25 years collective experience), reporting alignment (CEO and executive leadership), and third-party support (outsourced IT provider with virtual CTO/CISO). The primary focus is on who manages cybersecurity - the IT team and their qualifications/structure. This is Management Role.

Wait - is this more about the team composition and qualifications (Management Role) or about the third-party partnership (Third-Party Risk)? The paragraph splits between describing the internal IT team and the outsourced provider.

The team's experience and structure dominate here, so Management Role is the right fit. Looking at the specifics: the IT team has over 25 years of collective experience, the outsourced provider has been operating for over 23 years, and they specifically provide virtual CISO services—which is a concrete cybersecurity role. The CEO reporting line is mentioned generically, and the provider itself isn't named, but the CISO function is clearly identified.

Now I'm checking whether these numbers qualify as quantified-verifiable. Both the 25 years and 23 years are specific numbers, which the QV criteria does include. But there's a catch—"collective experience" is somewhat soft and hard to verify independently, and the unnamed provider's 23 years of operation can't really be verified without knowing who they are. The QV list does say specific numbers count, but these feel borderline since they lack the hard verifiability that named firms or specific certifications would have. Looking at the mention of CISO and virtual CISO services, that's clearly firm-specific information. The numbers here are precise but not independently verifiable in a hard sense, so I'm categorizing this as Firm-Specific rather than Quantified-Verifiable.

fact: over 25 years of collective experience in senior management

fact: virtual CTO and CISO services

fact: outsourced IT provider with over 23 years of operation


reasoning: The paragraph opens with an explicit materiality assessment ('have not experienced a cybersecurity threat or incident that resulted in a material adverse impact to our business or operations'), which per Rule 6 makes it Strategy Integration. The remainder is generic forward-looking language about potential costs of future incidents. No named entities, frameworks, dates, or firm-specific facts are present — entirely boilerplate language that could appear in any filing.

thinking:
Let me analyze this paragraph.

Content: This is a materiality assessment ("have not...experienced a cybersecurity threat or incident that resulted in a material adverse impact") combined with forward-looking risk language about potential future costs.

Category: The paragraph opens with a materiality disclaimer - explicitly assessing whether cybersecurity incidents have materially affected the business. Per Rule 6 and the codebook, this is Strategy Integration.

Specificity: No named frameworks, no firm-specific facts, no dates beyond "as of the date of this Report" (which is generic). All language is boilerplate. → Generic Boilerplate.


reasoning: The paragraph opens and closes with the Audit Committee as the primary actor — overseeing risk management, receiving reports on cybersecurity topics, and being informed of incidents above reporting thresholds. The CIO detail (named individual, 14 years experience, MBA, certifications) is substantial but subordinate to the board oversight frame, consistent with Case 5 guidance. For specificity, CIO is a cybersecurity-specific title and Mr. Kochavi is named with 14 years of experience (one QV-eligible fact), but 'multiple professional certifications' are unnamed and the MBA lacks a named university, so only one hard verifiable fact — yielding Firm-Specific, not Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Audit Committee oversight (Board Governance)
2. CIO identification, name, experience, credentials (Management Role)
3. CIO's responsibilities and reporting to Audit Committee
4. What the Audit Committee receives in reports (Board Governance)
5. Incident reporting thresholds to Audit Committee (Board Governance)

The paragraph opens with the Audit Committee, then shifts to a detailed description of the CIO (named individual, years of experience, credentials), then returns to what the Audit Committee receives.

Let me assess dominant category. The Audit Committee is the frame - it opens and closes the paragraph.

The CIO section is substantial but serves to establish who reports to the committee. The last two sentences are clearly Board Governance. I'd say this is roughly split but the Board Governance framing dominates - the Audit Committee is the primary actor in 3 of the 5 conceptual segments.

Actually, let me reconsider. The middle portion about Mr. Kochavi is quite detailed - name, 14 years experience, MBA, certifications. That's clearly Management Role content. But the paragraph's primary communicative purpose seems to be about the Audit Committee's oversight structure, with the CIO details providing context for who reports to them.

The opening really does set the frame - this is fundamentally about the Audit Committee's oversight responsibilities, and while the CIO information is substantial with specific details like his name and credentials, it's ultimately supporting that governance structure rather than being the main point. Counting it out, Board Governance dominates with three of the five sentences, while the two sentences on the CIO's background and qualifications are secondary to establishing the reporting relationship.

Looking at what qualifies as a quantifiable fact here, I've got the 14 years of experience as a specific number that counts, but the MBA without a named institution doesn't meet the threshold. The named individual and CIO title are information security facts, but they don't push this into quantifiable territory - I need more than one QV-eligible fact for that classification.

fact: CIO title (cybersecurity-specific role)

fact: Named individual: Mr. Oren Kochavi

fact: 14 years of experience


reasoning: The paragraph describes specific remediation and response actions taken 'upon detection' of an incident — credential rotation, MFA enforcement, DNS hardening, domain migration — which are all incident response activities describing what the company did after a real event. Despite the technical detail (SPF, DKIM, DMARC, DNSSEC), these are common security protocols and practices, not named frameworks from the Sector-Adapted list, and no named firms, tools, dates, or headcounts appear, leaving no facts from the IS list.

thinking:
Classifying this paragraph about incident response actions.

This describes specific remediation actions taken after detecting an incident. The paragraph is about what happened in response to a cybersecurity incident - credential rotation, MFA enforcement, account cleanup, DNS hardening, etc.

Content category: Incident Disclosure - describes response actions taken after detecting an incident.

Specificity: Let me check for specific facts.
- SPF, DKIM, DMARC - these are email authentication protocols/standards
- DNSSEC - a protocol
- MFA - common practice
- No specific dates, no named firms, no dollar amounts, no named tools/products, no named roles

- The email authentication protocols and DNSSEC are technical standards rather than governance frameworks like NIST or ISO 27001, so they don't fit the "named standard" category. The incident response measures described—credential rotation, MFA, domain locks—are standard security practices without specific product names, dates, or organizational details. The paragraph lacks any of the specific indicators that would push it beyond generic boilerplate—no third-party vendors, dates, product names, or team sizes. These are standard security practices, so Generic Boilerplate is the right classification.


reasoning: The paragraph primarily describes post-incident remediation actions (forensic investigation, access revocation, monitoring implementation, training) — these are incident response activities describing what was done after an event. The final materiality sentence is subordinate to the remediation narrative. No facts from the IS list are present: 'forensic investigation' is standard incident language, 'SIEM/SOC' are generic technology categories (not named products), 'quarterly' is a generic cadence, and no specific dates, named firms, named tools, headcounts, or dollar amounts appear.

thinking:
Let me analyze this paragraph carefully.

The paragraph describes remediation actions after an incident and includes a materiality assessment.

Content: forensic investigation completed, automated off-boarding/access-revocation, 24/7 SIEM/SOC monitoring, targeted training, domain/DNS/email stabilized, quarterly access reviews, ongoing monitoring. Final sentence: materiality assessment.

Category analysis:
- Describes post-incident remediation actions (what was done after an incident) → Incident Disclosure
- Has a materiality statement at the end → Strategy Integration
- Describes security processes implemented → Risk Management Process

The dominant content is describing what happened after an incident - remediation actions taken.

The materiality statement is just one sentence at the end, while the bulk of the paragraph focuses on the incident response and remediation steps taken. Applying the tiebreaker rule, since the paragraph primarily describes response actions from an incident, this falls under Incident Disclosure. The specific remediation measures—forensic investigation, automated access revocation, continuous monitoring, and training—are all standard incident response language rather than a list format.

Looking at the specificity markers: there are no named tools, no specific dates, no dollar amounts, no headcounts, no named frameworks, and no cybersecurity-specific titles. The terms used—SIEM/SOC monitoring, quarterly access reviews, domain and email operations—are all generic industry practices and common boilerplate language. Nothing here appears on the IS list, so this is Generic Boilerplate.


reasoning: The paragraph describes the company's internal cybersecurity training programs and topics covered, which are internal risk management processes. No named frameworks, cybersecurity-specific roles, or firm-specific facts are present — training topics like phishing, social engineering, and password protection are common practices found in any company's disclosure.


reasoning: The paragraph is a detailed narrative of an actual email spoofing incident — describing what happened, when, the financial loss, response actions, and remediation measures adopted. Multiple hard verifiable facts (four specific dates plus a dollar amount) clearly exceed the two-fact QV threshold.

thinking:
Classify this paragraph.

Content: Describes an actual email spoofing incident - dates, amounts, response actions. This is clearly Incident Disclosure.

Specificity: Let me count QV-eligible hard facts:
1. "April 9, 2024" - specific date
2. "$30,825" - dollar amount
3. "March 27, 2024" - specific date
4. "April 11, 2024" - specific date
5. "April 12, 2024" - specific date
6. CISO - named role (not QV-eligible, but firm-specific)

Multiple hard verifiable facts (dates + dollar amount) → Quantified-Verifiable

fact: April 9, 2024 — date incident information received

fact: April 11, 2024 — date Company verified the spoofing

fact: March 27, 2024 — date wire transfer was made

fact: $30,825 wire transfer amount

fact: April 12, 2024 — date remediation actions adopted

fact: Chief Information Security Officer


reasoning: The paragraph describes an actual cybersecurity incident — an email spoofing attempt in May 2014 — including the nature of the attack, how it was detected, and the outcome. The specific date (May 2014) is one hard verifiable fact, which reaches Firm-Specific but not QV (only one QV-eligible fact).

fact: email spoofing effort targeting a subsidiary's customer


reasoning: The paragraph describes a post-incident response action — filing reports with regulatory and enforcement agencies — which is part of incident response narrative. However, it contains no specific dates, no named agencies, no named legal counsel, and no details about which incidents, making it entirely generic boilerplate language.

thinking:
Classify this paragraph.

This describes reporting incidents to regulatory/enforcement agencies. It's about incident response actions - filing reports after cybersecurity incidents. This is Incident Disclosure (response actions taken after an incident).

Specificity: No dates, no named agencies, no named firms, no specific facts. "legal counsel" is generic. "regulatory and enforcement agencies" is unnamed. This is Generic Boilerplate.


reasoning: The paragraph's primary structure introduces the CISO with credentials (20+ years experience) and establishes the management hierarchy for cybersecurity oversight. While it also describes program scope and mentions board oversight, the dominant communicative purpose is identifying who manages cybersecurity risk and their qualifications — a Management Role paragraph. Specificity is Firm-Specific: CISO is a cybersecurity-specific title (IS list) and '20 years' is a specific number, but only one QV-eligible fact (years of experience; named roles don't count toward QV), so it does not reach Quantified-Verifiable.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Senior leadership responsibility for infosec risk
2. CISO with 20+ years experience leading cybersecurity team
3. CISO's responsibilities (program oversight)
4. Cross-functional collaboration
5. Board + C-suite oversight

The primary focus is on management's role - the CISO is described with credentials (20+ years experience), and the paragraph describes the management structure. But there's also significant process description and board mention.

Person-vs-function test: The paragraph mentions the CISO's experience (20 years) - that's about the person. But then it describes what the program does (risk management, operations, strategic planning, compliance) - that's about the function.

The cross-functional teams assessing risks represent the operational process layer. Looking at the structure more carefully, the CISO's credentials establish credibility, but the real substance is how the organization structures its cybersecurity function - what the program encompasses and how different parts of the company collaborate on risk management. The dominant theme here is really about who manages cybersecurity rather than what processes they use—the CISO and their credentials establish the management structure, while the process details are secondary. So Management Role is the right category. For specificity, "over 20 years of experience" is a concrete number that qualifies, though the CISO title itself doesn't count toward the QV threshold since named roles don't qualify. The C-suite titles and Board of Directors are too generic to be specific facts.

fact: Chief Information Security Officer (CISO)

fact: over 20 years of experience in cybersecurity and IT operations


reasoning: The paragraph describes the company's use of external consultants and auditors to assess and enhance its own cybersecurity posture — these third parties serve the company rather than being vendors whose security the company oversees. Per Rule 3, external assessors hired to test the company are Risk Management Process, not Third-Party Risk. No named firms, tools, frameworks, dates, or specific numbers are present; all language (penetration testing, vulnerability assessments, mitigation strategies) is generic.

thinking:
Classify this paragraph.

Content: About using third-party cybersecurity service providers and consultants for assessments, penetration testing, vulnerability assessments. Also mentions prioritizing mitigation strategies and using third-party tools.

Category: This is about third-party engagement, but the third parties here serve the company (consultants, auditors assessing the company's own security). Per Rule 3: "External assessor hired to test the company → Risk Management Process (they serve the company)." The central topic is the company's own risk assessment and enhancement practices using external help, not oversight of vendors' cybersecurity posture. → Risk Management Process

Specificity: No named frameworks, no named firms, no named tools, no dates, no numbers. Generic practices (penetration testing, vulnerability assessments). → Generic Boilerplate


reasoning: The paragraph describes the company's internal cybersecurity program processes — framework alignment, third-party assessments, and roadmap incorporation. While it mentions the Audit Committee, the primary content is about processes. NIST CSF is named but no firm-specific facts from the IS list are present (third-party consultant is unnamed, Audit Committee is generic, 'annually' is a generic cadence).

fact: NIST Cybersecurity Framework


reasoning: While the paragraph opens with board oversight language, the dominant content describes the company's internal risk management processes: ERM integration, NIST CSF-based risk assessment, qualitative risk methodology, and a cross-functional approach to cybersecurity. The board mention is contextual framing, not the primary communicative purpose. NIST CSF is a named standard triggering Sector-Adapted, but no firm-specific facts (no cybersecurity-specific roles, named tools, dates, or headcounts) push it higher.

thinking:
Let me analyze this paragraph carefully.

The paragraph covers multiple topics:
1. Board oversight of risk management (first few sentences)
2. NIST CSF framework usage and risk assessment methodology (middle)
3. General cross-functional approach to cybersecurity (end)

Primary communicative purpose: The paragraph starts with the board but quickly transitions to describing the company's risk management processes - ERM integration, NIST CSF, risk assessments, cross-functional approach. The board is mentioned as context, but the bulk is about processes.

Category: Risk Management Process (dominant content is about ERM integration, NIST CSF, risk assessment methodology)

Specificity level: Sector-Adapted. The paragraph names NIST CSF as a recognized standard, but lacks firm-specific details like named committees, particular tools, implementation dates, or internal governance structures beyond generic board references.


reasoning: The Audit Committee is the grammatical subject being informed and reported to, making this Board Governance. The CCO (Chief Compliance Officer) is not a cybersecurity-specific title per the IS list, 'Audit Committee' is explicitly generic, and 'at least once per quarter' is a generic cadence — no firm-specific facts remain after validation.

thinking:
Classify this paragraph.

The paragraph is about the Audit Committee receiving reports on cybersecurity matters. The Audit Committee is the primary subject being informed/reported to. This is Board Governance.

Specific facts:
- "CCO" - Chief Compliance Officer. This is not on the IS list for cybersecurity-specific titles. CCO is more like General Counsel - a generic C-suite role. Wait, let me check. The IS list says: "CISO, CTO, CIO, VP of IT/Security, Information Security Officer, Director of IT Security, HSE Director overseeing cybersecurity." CCO (Chief Compliance Officer) is not listed.

The CCO is just a generic corporate title, "Audit Committee" is explicitly excluded from the classification criteria, and the quarterly cadence is standard boilerplate language. Nothing here qualifies as specific cybersecurity governance details.


reasoning: The paragraph opens with an explicit materiality assessment ('not aware of any cybersecurity threats that have materially affected the Company, including its business strategy, results of operations or financial condition'), which triggers Strategy Integration per Rule 6. The remainder is generic forward-looking resource language and a cross-reference to Risk Factors, neither of which changes the classification. No firm-specific facts, named frameworks, or verifiable details are present.

thinking:
Materiality assessment present → Strategy Integration per Rule 6. Cross-reference appended doesn't change it.

Specifics: No named frameworks, no firm-specific facts. Boilerplate materiality language.


reasoning: The paragraph describes generic regulatory obligations (financial privacy laws, SEC 8-K disclosure rules) that apply to all regulated financial institutions and public companies. It names no company-specific processes, frameworks, or actions taken — only that regulations exist. It concludes with a cross-reference to another filing section. Per the codebook's Case 9 guidance, generic regulatory compliance language with no description of what the company does to comply is None/Other.

thinking:
Let me analyze this paragraph.

It describes regulatory compliance obligations - financial privacy laws, federal banking agency oversight, SEC disclosure rules. Then it has a cross-reference.

This is generic regulatory language - it describes what regulations apply but not what the company does. No specific frameworks, no company-specific facts. The cross-reference at the end points elsewhere.

Per the codebook's Case 9 guidance: "Regulatory Compliance" language that acknowledges regulations exist without describing any company-specific program → None/Other.

No materiality assessment, no process description, no specific facts.


reasoning: While the paragraph briefly describes the May 2020 ransomware incident (data removed from self-hosted environment), its dominant communicative purpose is the ongoing business/financial impact — legal proceedings, claims, potential judgments, settlements, fines, and penalties — with a cross-reference to financial statements for additional impact detail. The incident narrative is subordinate context for the strategy/materiality discussion. One hard verifiable fact (specific date: May 2020) yields Firm-Specific.

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

Content: Discusses a specific ransomware attack from May 2020, its ongoing legal consequences, and cross-references financial statements for impact details. This describes business/financial consequences (legal proceedings, settlements, fines) of a cyber incident rather than the incident narrative itself. The incident is briefly referenced but the main point is the ongoing legal/financial impact.

Wait - let me re-read. The paragraph describes: (1) learning from past incidents, (2) the May 2020 ransomware attack details (removed data from self-hosted environment), (3) legal proceedings and claims resulting from it, (4) cross-reference to Note 11 for impact.

The paragraph does describe what happened—ransomware attack, data removed from a self-hosted environment—but the real focus is on the consequences: legal proceedings, claims, potential judgments, and settlements. Since it includes both the incident description and the financial/legal impact discussion, I need to apply the tiebreaker rule. The section title "Actual and Potential Material Impact" suggests the dominant purpose is discussing consequences rather than disclosing the incident itself.

Looking at the text distribution, the legal and financial consequences take up significantly more space than the incident narrative. The incident details are brief context supporting the main point about business impact. I'm going to classify this as Strategy Integration because the paragraph's primary communicative goal is explaining the material consequences and ongoing legal exposure, not documenting what happened in the incident.

For specificity, I've got the May 2020 date as a concrete verifiable fact, plus the attack type and environment description, but no named systems, firms, dollar amounts, or headcounts. That puts it in the Firm-Specific category.

fact: May 2020 ransomware attack