ICFR & Disclosure Controls

Company response: We hereby confirm that in future periodic filings, we will revise our officer certifications to include introductory language within paragraph 4 and the entirety of paragraph 4(b) pertaining to internal control over financial reporting. We appreciate the assistance the Staff has provided with its comments. response letter →

Company response: We acknowledge the Staff’s comment. In future Annual Reports on Form 10‑K and Quarterly Reports on Form 10‑Q, we will revise our disclosure under “Controls and Procedures” to explicitly state management’s conclusion regarding the effectiveness of our disclosure controls and procedures as of the end of the period covered by the report, as required by Item 307 of Regulation S‑K. 1 By way of example, we expect to include language substantially similar to the following (subject to updates as of each reporting date): “As of _______________, our management, with the participation of our Chief Executive Officer and Chief Financial Officer, evaluated the effectiveness of our disclosure controls and… response letter →

Company response: 1 to our Form 20-F for the fiscal year ended April 30, 2025. Upon identifying the need to amend our original Form 20-F to include the previously omitted items, management, including our principal executive officer and principal financial officer (the “Certifying Officers”), re-evaluated the effectiveness of our disclosure controls and procedures (“DCP”) as of April 30, 2025. This re-evaluation was conducted specifically to determine whether the omission of these items from the original filing indicated a material weakness or a significant deficiency in our DCP that would alter the original conclusion of effectiveness. The re-evaluation considered the following factors: 1. Nature of the… response letter →

Company response: We have revised our disclosure in Item 15 of Part II to the Form 20-F. response letter →

Company response: We acknowledge the Staff’s comment and will revise future filings accordingly. To the extent that the material weakness remains unremediated, in future filings, we intend to address this comment substantially consistent with the following: Our Chief Executive Officer and Chief Financial Officer (“certifying officers”) have conducted an evaluation of the effectiveness of the design and operation of our disclosure controls and procedures (as defined in Rules 13a-15(e) and 15d-15(e) under the Securities Exchange Act of 1934, as amended (the Exchange Act)) as of [Reporting Date]. Our certifying officers concluded that, as a result of the material weaknesses in internal control over financial… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that in connection with management’s evaluation of the Company’s internal control over financial reporting as of the end of the period ending December 31, 2024, management concluded that as of such date, our internal control over financial reporting was effective. In addition, the registered public accounting firm that audited the financial statements included in our Form 10-K issued an attestation report that included an opinion that we maintained, in all material respects, effective internal control over financial reporting as of December 31, 2024, based on criteria established in the 2013 Internal Control – Integrated… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and notes that this disclosure was inadvertently omitted from its Form 10-K due to a typographical error. On December 10, 2025, the Company filed Amendment No. 1 to Annual Report on Form 10-K/A to disclose management’s assessment regarding the effectiveness of its internal control over financial reporting as of December 31, 2024. response letter →