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Tuesday, 12/06/2016 7:56:41 PM

Tuesday, December 06, 2016 7:56:41 PM

Post# of 144812
FROM THE MOST RECENT 10q pg 26

Under the supervision and with the participation of the Principal Executive Officer and the Vice President of Finance, management conducted an evaluation of the effectiveness of our internal control over financial reporting as of October 31, 2016 based on the criteria outlined in Internal Control-Integrated Framework (2013) issued by the Committee of Sponsoring Organizations of the Treadway Commission (“COSO”) and identified the following material weaknesses in internal control over financial reporting:

· Ineffective corporate governance;
· Ineffective communication of internal information;
· Insufficient procedures and control documentation;
· Insufficient segregation of duties; and
· Insufficient information technology controls and documentation.

Because of these material weaknesses, the Principal Executive Officer and Acting Principal Financial Officer and the Vice President of Finance concluded that, as of October 31, 2016, our internal control over financial reporting was not effective based on the COSO criteria.
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