6.06 Exhibit index omits the Exhibit 104 row and the word 'Inline' in the XBRL exhibit titles (both years)
Company D · a US-listed cloud communications software company · Drafting slip
In brief
The exhibit index stops at [n].PRE with no row for Exhibit 104 (Cover Page Interactive Data File), and the XBRL rows are titled 'XBRL Taxonomy ...' without the word 'Inline'; the cover data were tagged and filed, and the prior-year index had the same layout.
The evidence, as filed
What the filing shows, and what the rule requires
| What the filing shows | What the rule requires |
|---|---|
Exhibit index ends at '[n].PRE XBRL Taxonomy Extension Presentation Linkbase Document.'; no Exhibit 104 row; [n].SCH titled 'XBRL Taxonomy Schema Document.' | Add '[n] Cover Page Interactive Data File (formatted as Inline XBRL and contained in Exhibit 101)' and title the XBRL rows 'Inline XBRL Taxonomy ...'. |
The rule
Regulation S-K Item 601(a)(2)
For convenient reference, each exhibit shall be listed in the exhibit index according to the number assigned to it in the exhibit table.
Version: Text in force at the date of this review · Source: Regulation S-K, 17 CFR 229.601 (eCFR, as amended)
Regulation S-K Item 601(b)(104)
Cover Page Interactive Data File. A Cover Page Interactive Data File (as defined in § [n] of this chapter) as required by Rule 406 of Regulation S-T (17 CFR 232.406), and in the manner provided by the EDGAR Filer Manual.
Version: Text in force at the date of this review · Source: Regulation S-K, 17 CFR 229.601 (eCFR, as amended)
Regulation S-K Item 601(b)(101), Instruction 1 to paragraphs (b)([n])(i) and (ii)
the exhibit index must include the word “Inline” within the title description for any eXtensible Business Reporting Language (XBRL)-related exhibit.
Version: Text in force at the date of this review · Source: Regulation S-K, 17 CFR 229.601 (eCFR, as amended)
Why it applies here. An index-labelling slip carried from the prior year: the company's own Form 8-K of the same day lists Exhibit 104, and the filed Inline XBRL carries the cover-page tags, so nothing is missing from the filing itself.
Why it matters
None beyond a tidier exhibit index.
Exposure
None beyond correcting the index in the next Form 10-K.
Management’s best defense, and our reply
The cover page was tagged in Inline XBRL and accepted by EDGAR, so every investor and data user received the cover data, and the [n].INS row already explains that the tags are embedded in the Inline XBRL document. The prior-year filing used the same index without comment, so the practice can be read as settled. However, Item 601(a)(2) requires each exhibit to be listed under its number and the Instruction to Item 601(b)(101) requires the word 'Inline' in each XBRL title; the company's own Form 8-K of the same date shows the row it omits, and the fix is two lines of the index.
The fix
- Add '[n] Cover Page Interactive Data File (formatted as Inline XBRL and contained in Exhibit 101)' to the index and retitle the rows 'Inline XBRL Taxonomy Extension ... Document'.
Evidence relied on
| # | What it shows | Type | Where |
|---|---|---|---|
| 1 | The filing uses Inline XBRL; only the [n].INS row mentions it | Document | Form 10-K 2025, page 130 |
| 2 | The schema exhibit is titled without the word 'Inline' | Document | Form 10-K 2025, page 130 |
| 3 | The index ends at [n].PRE, before the footnotes, with no Exhibit 104 row | Document | Form 10-K 2025, page 131 |
| 4 | The Form 8-K filed the same day lists Exhibit 104 in its exhibit list | Document | |
| 5 | The company's own Form 8-K filed the same day lists Exhibit 104 in its exhibit list | Document |
Absence check
- Document
- Form 10-K 2025
- Where it would appear
- [n].LAB
- What is missing
- Exhibit 104, the Cover Page Interactive Data File, as a row of the exhibit index
- Pages looked at
- p.128-131 (Exhibit Index) and the cover page unnumbered page
- Result
- '[n]' hits only the figure [n] on p.65 and p.84 and the printed folio [n] on p.104; 'Interactive Data' hits only the cover-page check box on Rule 405 submissions (unnumbered page) and the [n].INS description on p.130; 'Cover Page' and 'Exhibit 104' do not hit.
Prepared by Pramanex from the company’s public SEC filings, without the company’s involvement, to show how a 10-K Pre-filing Check reads. The company is not named, and nothing on this page is a statement about any identifiable company. Observations are not an audit, review or other attestation or assurance engagement, and not legal advice. An SEC-style question is a question, not a conclusion.
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