Contract analysis

1. Introduction and Filing Reference The FINRA Corporate Financing Department (the "Department") refers to the filing submitted by Whitfield Barrow & Co., LLC (FINRA CRD No. 7924) ("Whitfield Barrow" or the "Representative"), on behalf of the underwriting syndicate identified herein, in connection with the proposed initial public offering (the "Offering") of shares of common stock, par value $0.001 per share (the "Sh

2. Description of Offering Terms Reviewed The Department has reviewed the following material terms and conditions of the Offering as set forth in the Registration Statement and the FINRA Rule 5110 filing materials: Security: Common stock, par value $0.001 per share, CUSIP 039217105. Number of Shares Offered (Base Offering): 20,000,000 shares of common stock, all of which are to be offered in a primary issuance by the

3. Identification of Participating Underwriters and Allocations The Department has reviewed the composition of the underwriting syndicate and the allocation of shares among the participating underwriters. Based on the information provided in the filing, the underwriting syndicate and share allocations are as follows: The overallotment option shares, if and to the extent exercised, would be allocated among the underwr

4. Review of Underwriting Compensation and Arrangements The Department has reviewed the underwriting compensation and related arrangements in connection with the Offering, including the following: Underwriting discount. The underwriting discount is 6.0% of the public offering price per share. By way of illustration, based on a public offering price of $20.00 per share, the underwriting discount would be $1.20 per sha

5. Review of Affiliations and Conflicts of Interest The Department has reviewed the information disclosed in the FINRA Rule 5110 filing and the Registration Statement regarding the relationships between the participating underwriters and the Issuer, including any affiliations or other material relationships with pre-IPO investors of the Company, specifically Brindoval Trelvon Partners, L.P. and Ridgeline Growth Equit

6. No-Objections Determination Based on the information submitted in the FINRA Rule 5110 filing and all amendments and supplements thereto received by the Department through the date hereof, including the representations and certifications provided by Whitfield Barrow & Co., LLC on behalf of the underwriting syndicate, the FINRA Corporate Financing Department has determined that it has no objection to the underwritin

7. Conditions and Qualifications This letter and the Department's no-objections determination are subject to the following conditions and qualifications: (a) This letter is based exclusively on the information provided in the FINRA Rule 5110 filing, including all amendments and supplements thereto, received by the Department as of the date hereof. The Department has relied upon the accuracy and completeness of the in

8. Contact Information and Filing Records The Department's review of this filing was conducted by the undersigned analyst. Any questions regarding this letter, the Department's determination, or subsequent filings in connection with the Offering should be directed to the FINRA Corporate Financing Department at the contact information set forth below: FINRA Staff Reviewer: Catherine R. Delacroix, Senior Analyst FINRA