ASC 606: Revenue Recognition

Company response: The Company acknowledges the Staff’s Comment and respectfully advises the Staff that the Company tracks external research and development expenses on a clinical trial-specific basis while aggregating such expenses for its preclinical studies. The Company undertakes to provide disclosure substantially in the form presented below in its future filings with the Commission. Research and development expenses consist primarily of costs incurred for the discovery and development of our product candidates. Given the number of programs that we have and, because some of our clinical trials may combine more than one program, we track the external research and development costs incurred per clinical… response letter →

Company response: The Company respectfully advises the Staff that, upon inception of the 2023 Gilead License Agreement, it identified three performance obligations. The agreement also provided Gilead with an option to purchase drug supply of GS-0321. The Company concluded that this option did not provide a material right and therefore did not represent a separate performance obligation. During the first half of 2026, Gilead exercised its option to purchase additional goods and services related to the supply of GS-0321. The Company undertakes to update its disclosure in future filings with the Commission to reflect the exercise of this option. The Company further advises the Staff that revenue associated with… response letter →

Company response: The Company respectfully acknowledges the Staff’s comment and confirms that future annual reports on Form 20-F, including our Annual Report on Form 20-F for the fiscal year ending September 30, 2026, will disclose when we expect to recognize remaining performance obligations as revenue on a quantitative basis using time bands that would be most appropriate for the duration of the remaining performance obligations. A portion of the Company’s revenue relates to projects for which revenue is recognized over time based on a percentage that incurred labor effort to date bears to total projected labor effort. These projects may be executed over periods longer than one year, and the timing of… response letter →

Company response: We generate revenue from the sale of carbon credits and from consulting and related services. Our environmental attributes are both compliance focused (such as Canada Federal OBPS or Alberta TIER) and voluntary focused (transacted withing Gold Standard, Verra, etc.). We apply ASC 606, Revenue from Contracts with Customers , to these arrangements. (1) Nature of the carbon credits Our contracts with customers typically involve the sale of environmental attributes that are either: · Project generated credits: Credits we originate or control through our participation in underlying projects (e.g., afforestation, reforestation, or other verified emissions reduction projects); or · Purchased… response letter →

Company response: , describe how you assessed the indicators outlined in ASC 606‑10‑55‑36 through 55‑40. Response: We acknowledge the Staff’s comment and have evaluated whether we act as principal or agent in our carbon credit transactions under ASC 606‑10‑55‑36 through 55‑40. In most of our carbon credit sales, we conclude that we are the principal because we control the credits before they are transferred to the customer. Our assessment is based on the following indicators: · Control of the asset before transfer (ASC 606‑10‑55‑37): We obtain control of the credits either by (i) originating them through our project arrangements, or (ii) purchasing them from third parties and holding them in our registry… response letter →

Company response: We acknowledge the Staff’s comment. We recognize that ASC 606‑10‑50‑8 through 50‑10 requires disclosure of the opening and closing balances of contract liabilities (deferred revenue), significant changes in those balances, and information about the timing of revenue recognition for remaining performance obligations. Below is a roll forward as requested. FY2025 (Year Ended May 31, 2025) Q2 FY2026 (Six Months Ended Nov 30, 2025) Opening balance $ - $ 3,864,080 Heidelberg deferred revenue $ 928,042 $ (928,042 ) DevvStream deferred revenue $ 2,936,038 $ - Other deferred revenue $ - $ 26,764 Currency translation $ - $ (47,901 ) Closing balance $ 3,864,080 $ 2,914,901 Current portion $ 3,864,080… response letter →

Company response: We acknowledge the Staff’s comment. We agree that our revenue should be disaggregated to depict how the nature, amount, timing, and uncertainty of revenue and cash flows are affected by economic factors, as required by ASC 606‑10‑50‑5 and 55‑89 through 55‑91. In future Annual Reports on Form 10‑K and, where material, Quarterly Reports on Form 10‑Q, we will disaggregate revenue by type of good or service and, if relevant, by geographic region or market. We will also provide the required narrative discussion linking the disaggregated revenue to our segment information (if applicable) and to our revenue recognition policies. Form 10‑Q for the Quarter Ended November 30, 2025 6 Item 2.… response letter →

Company response: letter, specifically your response to comment four. You state that you disaggregate your revenue based on type of good or service (e.g., manufacturing and license fees) and regulatory pathway (e.g., ANDA vs NDA). Please address the following: ● Given that you have paused further development of NDAs and do not appear to have engaged in business activities in this segment since 2021, explain to us how disaggregation by regulatory pathway provides a meaningful level of disaggregation of your revenues. U.S. Securities and Exchange Commission ● In your February 20, 2024 response to prior comment four, you stated that when determining the level of revenue disaggregation, you considered the… response letter →

Company response: The Company respectfully advises the Staff that with respect to the defects liability period, the clients of the Company's operating subsidiary may retain up to 5% to 10% of each payment to be made to the operating subsidiary, as retention monies. The defects liability period does not represent a separate performance obligation and therefore does not impact the timing of revenue recognition. The defects liability period is merely a warranty in nature, and it is not an additional service provided to the customer. It does not increase the scope of work done in a construction project, and does not constitute a distinct service. Revenue is recognized when the construction work services were… response letter →

Company response: The Company confirms that management considered Rule 5-03(b) of Regulation S-X and the guidance under ASC-606-10-50-5, ASC 606-10-55-89 through 55-91 and ASC 280-10-50-40 in evaluating the Company’s presentation of revenue and costs of revenue. In evaluating the presentation of revenues and costs of revenues under Rule 5-03(b) of Regulation S-X, management considered whether the Company’s revenues from products, services, and other activities warrant separate presentation on the face of the consolidated statements of operations. Rule 5-03(b) of Regulation S-X provides that “ if income is derived from more than one of the sub-captions described under § 210.5-03.1, each class which is not… response letter →

Company response: addresses principal versus agent considerations as discussed in ASC 606-10-55-36 through 40. Response: We have expanded our disclosures in the Summary of Significant Accounting Policies - Revenue Recognition in footnote 2 to Notes to Unaudited Condensed Consolidated Financial Statements and in Item 2. Management’s Discussion and Analysis of Financial Condition and Results of Operations - Critical Accounting Policies End estimates in our Form 10-Q for the first fiscal quarter ended November 30, 2025 filed on January 14, 2026, and will continue disclosing them plus the new language in brackets below in our future filings. We added the following disclosures: Gross Versus Net Revenue ASC 606… response letter →

Company response: The Company respectfully clarifies that the previously disclosed “gross amount of revenue” was intended as an operational metric. In response to the Staff’s comment, the Company respectfully undertakes to revise the relevant disclosure in its future Form 20-F filings as follows (with deletions shown in strikethrough showing the changes against the disclosure in the 2024 Form 20-F), subject to such updates and adjustments to be made in connection with any material developments of the subject matter being disclosed. “ NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS … 2. SUMMARY OF SIGNIFICANT ACCOUNTING POLICIES … (s) Revenue recognition … 5 CPaaS revenues The Company accounts for revenue from… response letter →