23E003 Helmets May Not Adequately Protect User – Bilt Route BLH100, Bilt Route Retro Womens BLH118, & Bilt Route Journey BLH109 Helmets

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OMB Control No.: 2127-0004 Part 573 Safety Recall Report 23E-003 The information contained in this report was submitted pursuant to 49 CFR §573 Manufacturer Name : Comoto Holdings, Inc. Submission Date : JAN 13, 2023 NHTSA Recall No. : 23E-003 Manufacturer Recall No. : NR Manufacturer Information : Manufacturer Name : Comoto Holdings, Inc. Address : 4020 S 26th St Philadelphia PA 19112 Company phone : 1-800-292-5343 Population : Number of potentially involved : 18,980 Estimated percentage with defect : 5 % Equipment Information : Brand / Trade 1 : BILT HELMET Model : BILT ROUTE HELMET Part No. : BLH100 Size : MD, XL, XXL Function : Head Protection Descriptive Information : A few helmets failed to comply during DOT testing. Penetration Test Failure. Potential quantity involved 14,466 Production Dates : MAR 01, 2020 – JAN 01, 2022 Brand / Trade 2 : BILT HELMET Model : BILT ROUTE RETRO WOMENS HELMET Part No. : BLH118 Size : MD, XL, XXL Function : Head Protection Descriptive Information : A few helmets failed to comply during DOT testing. Penetration Test Failure. Potential quantity involved 1,829 Production Dates : MAR 01, 2020 – JAN 01, 2022 Part 573 Safety Recall Report 23E-003 Page 2 The information contained in this report was submitted pursuant to 49 CFR §573 Brand / Trade 3 : BILT HELMET Model : BILT ROUTE JOURNEY Part No. : BLH109 Size : MD, XL, XXL Function : NR Descriptive Information : A few helmets failed to comply during DOT testing. Penetration Test Failure. Potential quantity involved 2,685 Production Dates : MAR 01, 2020 – JAN 01, 2022 Description of Noncompliance : Description of the Noncompliance : Penetration test Failure FMVSS 1 : 218 – Motorcycle helmets FMVSS 2 : NR Description of the Safety Risk : Penetration test Failure: Very rare safety risk. There is an increased risk of a rider suffering a head injury if the helmets were to fail Description of the Cause : NR Identification of Any Warning that can Occur : NR Involved Components : Component Name : NR Component Description : NR Component Part Number : NR Supplier Identification : Component Manufacturer Name : Foshan City Nanhai Manufacturing Co Ltd Address : Yannan Industrial Area Longgao Road, Jiujiang Foshan City Foreign States Country : China Part 573 Safety Recall Report 23E-003 Page 3 The information contained in this report was submitted pursuant to 49 CFR §573 Chronology : 04/22 Comoto were notified that the sizes M, & XXL helmet manufactured in 2021 that were tested at ACT Lab USA were found to be noncompliant with FMVSS 218. 06/22 after discussion with the manufacturer, Foshan City Nanhai Manufacturing Co Ltd. Comoto submitted a further M size for compliance testing. ACT reported to COMOTO that this size had also failed the penetration tests. Comoto notified Foshan City Nanhai Manufacturing again of the failure and they started to do some investigation internally and in August they provided ACT Labs China with improved liners in the Route helmets. These all passed (XS, S, M, L, XL, XXL) The vendor then sent sizes S, M, L, XL, XXL to Comoto to submit for retesting at ACT Labs USA. We were notified in October that the three sizes M, XL, and XXL had failed to comply. Comoto was very surprised by the noncompliance because the model helmet had passed testing in ACT Lab China Oct, 2016, June, 2017, June 2018, December, 2018, May 2019, December, 2019. After reviewing all tests, Comoto decided to voluntarily initiate this recall. Description of Remedy : Description of Remedy Program : Will provide owners of the recalled helmets with either. 1) a replacement BILT model helmet which complies with FMVSS218; or 2) other model helmet of equal or lesser value 3) A Credit; How Remedy Component Differs from Recalled Component : Helmets manufactured in the last 3 years Identify How/When Recall Condition was Corrected in Production : N/A Recall Schedule : Description of Recall Schedule : Please note COMOTO has no dealer network Planned Dealer Notification Date : JAN 13, 2023 – JAN 13, 2023 Planned Owner Notification Date : FEB 01, 2023 – MAR 01, 2023 Purchaser Information : The following manufacturers purchased this defective/noncompliant equipment for possible use or installation in new motor vehicles or new items of motor vehicle equipment: Name : NR Address : NR NR Country : NR Company Phone : NR * NR – Not Reported

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􀀆CO!WOTO @J!iiP> ….. IMPORTANT SAFETY RECALL The NHTSA Safety Recall numbers are 23E003 and 23E004 Dear Cycle Gear I Revzilla / J&P Cycles Customers: This notice is sent to you in accordance with the National Traffic Safety and Motor Vehicle Safety Act. Comoto Holdings, Inc., has decided that certain BILT Vertex and BILT Route motorcycle helmets fail to conform to Federal Motor Vehicle Safety Standard No. 218, “Motorcycle helmets.” Your safety is our biggest concern, and we always strive to ensure that the products we sell exceed the applicable safety standards. We are writing to you today regarding an important product recall issue relating to a small range of helmets sold by us. This recall is being conducted according to rules and procedures of the National Highway Traffic Safety Administration (“NHTSA”) and the U.S. Department of Transportation (“DOT”). The NHTSA Safety Recall number 23E003 and 23E004 . Please read this communication carefully as it informs you as to what you should do in connection with the recalled helmets. WHAT IS THE DEFECT /NONCOMPLIANCE? Our third-party testing company determined that some of the helmets did not comply with Federal Motor Vehicle Standards. The helmets may not provide adequate impact protection in the event of a crash, increasing the risk of injury. For that reason, we are recalling the following helmets: • BILT Vertex Helmets produced after 9/1/2021 in the following sizes o BILT Vertex – SM, MD, LG, XL o BILT Vertex Parabola Helmet- SM, MD, LG, XL o BILT Vertex Stripes Helmet- SM, MD, LG, XL • BILT Route Helmets produced after 3/1/2020 in the following sizes o BILT Route – MD, XL, XXL o BILT Route Retro Womens Helmet- MD, XL, XXL o BILT Route Journey Helmet- MD, XL, XXL If you have one of the helmets listed above, then you should stop using that helmet immediately. Also, you should be aware that it is a violation of federal law for you to sell any helmet covered by this recall notice.

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