Item 1C cybersecurity disclosure from a small-staff registrant stating it has no formal cybersecurity risk management program beyond antivirus/antimalware, with information security managed by its CEO and sole director. The filer explicitly states it has not been the victim of a cyber incident in the past. No breach is disclosed.
About this clustering
DisclosureLens links filings into incidents through layered matchers: deterministic rules (same source document, multistate filings of one breach, tight-window same-victim pairs), a weighted-similarity scorer for cross-source candidates, and an operator review queue for everything uncertain. Each link records its own method and confidence — shown per filing in the timeline below. The system defaults to NOT merging when uncertain, because a false merge (collapsing two unrelated breaches) is more harmful than a false split (showing related filings separately); uncertain pairs route to human review instead of auto-merging. Filing summaries shown in the timeline are AI-generated extracts — verify each against its linked source.