could history be repeating itself? tick tock ht

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Item 9A. Controls and Procedures, page 16
1. We are reissuing our prior comment. We note your revised disclosure including the section - Management's Report on Internal Control over Financial Reporting however, your disclosure is not consistent with Item 308(a) of Regulation S-K or Rules 13a-15(f) of the Exchange Act. Please revise accordingly. Additionally, we note you revised several areas within the the section - Evaluation of Disclosure Controls and Procedures. However, in doing so it appears you have commingled the disclosure requirement of Item 307 Disclosure Control and Procedures with Item 308 Internal control over financial reporting . Please revise accordingly to separately provide the disclosure requirements of Items 307 and Item 308 of Regulation S-K.

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