IP Forensics, LLC v. Colt's Manufacturing Company LLC

Filing 1

COMPLAINT against Colt's Manufacturing Company LLC ( Filing fee $ 350 receipt number 0540-3056109.), filed by IP Forensics, LLC. (Attachments: # 1 Exhibit, # 2 Exhibit, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Civil Cover Sheet)(Konczal, Michael)

EXHIBIT D

IMPORTANT PRODUCT RECALL NOTICE

Colt’s Manufacturing Company LLC has determined that the Slide Lock
Safety (“Safety”) and/or the Recoil Spring Guide Pad (“Guide Pad”) in certain
Colt model pistols were not manufactured to Colt specifications and must be
replaced. All of these Colt models were sold after March 2007 and the range of
serial numbers affected by this product recall is as follows:
Model

Serial Number Range

1911 WWI REPLICA (O1911)
4597WMK to 5414WMK
1918 WWI REPLICA (O1918)
1001WWI to 3431WWI
COMBAT ELITE (O8011XSE)
CG10000E to CG11293E
NEW AGENT (O7810D)
GT01001 to GT04505
DEFENDER (O7000D)
DR33036 to DR35948
TALO NIGHT DEFENDER (O7000NDF) NDF0001 to NDF0400

Safety
X
X
X
X

Guide Pad

X
X
X

In the chart above, an “X” beneath “Safety” and/or “Guide Pad” signifies that the
part(s) of the listed model needs replacement. Only the NEW AGENT model
needs replacement of both parts.
For all models listed above, except the DEFENDER and the NIGHT
DEFENDER models, you must return the pistol to the Colt factory for
part(s) replacement. The DEFENDER models do NOT need to be returned.
Instead, we will send you a new Recoil Spring Assembly Kit that includes
the Guide Pad to replace in your pistol. See the instructions below on how
to obtain recall service.
The Safety is located on the left side of the pistol just below the slide:
Slide Lock Safety

June 29, 2009 (7/1 Rev.)

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EXHIBIT D

The Guide Pad is located at the end of a recoil spring assembly, which is
positioned inside the slide between the recoil spring bushing and the barrel lug.
On the recoil spring assembly, the Guide Pad looks like this:

Recoil Spring Guide Pad

Outer Recoil Spring

Recoil Spring Assembly Kit

Colt has determined that the Safety and the Guide Pad in the affected pistols are
of improper hardness. As a result, the Safety can prematurely wear or bend,
especially if the pistol is dropped, possibly rendering the Safety incapable of
preventing an accidental firing, and the Guide Pad might crack and possibly
prevent the pistol from firing. Although there have been no reports of personal
injuries or property damage, safety is our number one concern. Therefore, the
affected pistols should not be loaded or used until the Safety and/or Guide Pad
have been replaced.
If you own one of these Colt models with a serial number listed above, please
STOP USING YOUR FIREARM AT ONCE. Then, follow the instructions below
to return it to us so that we can replace the firearm part(s) AT NO COST TO
YOU.

FOR THE FOLLOWING MODELS:
1911 WWI REPLICA (O1911)
1918 WWI REPLICA (O1918)
COMBAT ELITE (O8011XSE)
NEW AGENT (O7810D)
1.

Contact Colt Customer Service for instructions on how to return the
pistol to us and to obtain a mailing label so you can send it to us
FREE OF CHARGE. Please provide us with your model and serial

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EXHIBIT D

number. Customer Service can be reached by any of the following
means:
i Complete our online form by going to Colt’s website at
www.coltsmfg.com/.
i E-mail us at [e-mail].
i Call Monday-Friday, 8:30AM–12:00PM; 1PM–5PM EST, 1-800962-COLT (2658), press Option “2”.
i Write us at Colt’s Manufacturing Company LLC, 545 New Park
Avenue, West Hartford, CT 06110.
2.

Follow Customer Service’s instructions to send the gun back to us.

3.

We will replace the Safety (and, on NEW AGENT models only,
install a new Recoil Spring Assembly Kit that includes replacement
of the Outer Recoil Spring and Guide Pad) and return your firearm
to you as quickly as possible.
Note: We cannot return your firearm to a P.O. Box address.
Therefore, we will need your street address where the firearm will
be returned.

4.

DO NOT LOAD OR USE YOUR FIREARM until we have
performed this repair.

5.

DO NOT ATTEMPT TO MAKE THIS REPAIR YOURSELF. The
Slide Lock Safety must be replaced at the factory in order to be
done properly.

For 1911 WWI REPLICA and 1918 WWI REPLICA models on which the Slide
Lock Safety has been replaced, our gunsmiths will stamp a small “-“ on the inside
right rear of the slide, directly below the extractor, as confirmation that the retrofit
has been performed. For COMBAT ELITE models on which the Slide Lock
Safety has been replaced, our gunsmiths will stamp a small pennant “ ” on the
bottom right side of the trigger guard. NEW AGENT models on which both the
Slide Lock Safety and Recoil Spring Guide Pad have been replaced will have two
marks. Our gunsmiths will stamp a small pennant “ ” on the bottom right side of
the trigger guard as confirmation that the Slide Lock Safety retrofit had been
performed. The new Recoil Spring Guide Pad has a small dimple appearing on
the top left, rear-facing, surface of the pad.

FOR DEFENDER MODELS ONLY, INCLUDING THE TALO NIGHT
DEFENDER (O7000D and O7000NDF)

EXHIBIT D

-4-

You do not need to return the DEFENDER model pistols to Colt. We will provide
you with a free Recoil Spring Assembly Kit and instruct you how to install it
yourself. If you would like us to install the kit for you, please make this request of
Colt Customer Service. In either case, please take the following steps:
1.

Contact Colt Customer Service for instructions on how to receive a
free Recoil Spring Assembly Kit or obtain a mailing label to return
the pistol to us. In either situation, we will replace this assembly
FREE OF CHARGE. Please provide us with your model and serial
number. Customer Service can be reached by any of the following
means:
i Complete our online form by going to Colt’s website at
www.coltsmfg.com.
i E-mail us at [e-mail].
i Call: Monday-Friday 8:30AM–12:00PM; 1PM–5PM EST: 1-800962-COLT (2658), press Option “2”.
i Correspond with us via US Postal Service at Colt’s
Manufacturing Company LLC, 545 New Park Avenue, West
Hartford, CT 06110.

2.

Follow Colt Customer Service’s instructions and prompts on how to
receive a Recoil Spring Assembly Kit or how to send the gun back
to us. Please be ready to provide the Colt model and serial
number.
Note: We cannot return your firearm to a P.O. Box address.
Therefore, we will need your street address where the firearm will
be returned so that we can return it to you as quickly as possible.

3.

DO NOT LOAD OR USE YOUR FIREARM until this repair has
been performed. .

Please note that, apart from this recall, we designed a symmetrical Outer Recoil
Spring with closed ends on each side for the NEW AGENT and DEFENDER
models. This design allows the spring to be inserted from either end into the
recoil bushing. This replacement spring will be included as part of the Recoil
Spring Assembly Kit being furnished in this recall. The new Recoil Spring Guide
Pad has a small dimple appearing on the top left, rear facing, surface of the pad
that will serve as confirmation that the retrofit has been performed.
In closing, Colt’s Manufacturing Company LLC is fully committed to the quality of
its products and the safety of its customers. We regret very much the
inconvenience that this situation is causing to our valued customers.