Resolute/Tungsten Disclose ~42% Beneficial Stake in CompoSecure (CMPO)

Rhea-AI Filing Summary

Amendment No. 4 to Schedule 13D updates beneficial ownership details for Class A Common Stock of CompoSecure, Inc. The reporting persons state the amendment is solely due to a change in the aggregate number of Class A shares outstanding and not due to any new transaction by them. Resolute Compo Holdings LLC holds 49,290,409 shares (41.0% of Class A). Tungsten 2024 LLC and Thomas R. Knott each report beneficial ownership of 49,937,302 shares (41.5%). John D. Cote reports 51,437,302 shares (42.8%), reflecting an additional 1,500,000 shares held by Ridge Valley LLC. The row percentages are based on 120,239,665 Class A shares outstanding as of August 27, 2025. Tungsten is the managing member of Resolute Compo Holdings and has voting/dispositive rights subject to consultation rights held by Mr. Knott.

Positive

• Material disclosure of substantial ownership: Resolute Compo Holdings, Tungsten 2024 LLC, Thomas R. Knott, and John D. Cote disclose combined meaningful stakes (41.0%–42.8%) of Class A stock.
• Clarifies control relationships: Filing explains that Tungsten is managing member of Resolute Compo Holdings and describes voting/dispositive rights and consultation rights for Mr. Knott.
• Amendment due to share count change only: Reporting persons state the amendment results solely from a change in outstanding shares, not new transactions by them.

Negative

• None.

Insights

Financial Analyst

TL;DR: A coordinated group controls roughly 41-43% of Class A shares, a sizeable, potentially influential stake.

The reporting persons disclose substantial shared beneficial ownership of CompoSecure Class A stock driven by record holdings in Resolute Compo Holdings and Tungsten. The filings emphasize that this amendment reflects an increase in the denominator

Corporate Governance Expert

TL;DR: The filing clarifies ownership structure and control arrangements, important for shareholder governance.

The amendment provides clear attribution of record and shared holdings across affiliated entities and individuals, specifying voting and dispositive power allocations and consultation rights. Disclosure that the filing results from a change in total outstanding shares

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

SCHEDULE 13D

Under the Securities Exchange Act of 1934

(Amendment No. 4)

CompoSecure, Inc.

(Name of Issuer)

Class A Common Stock, $0.0001 Par Value per share

(Title of Class of Securities)

20459V105

(CUSIP Number)

Thomas R. Knott
c/o Resolute Compo Holdings LLC, 445 Park Avenue, Suite 5B
New York, NY, 10022
(212) 256-8405

(Name, Address and Telephone Number of Person Authorized to Receive Notices and Communications)

08/25/2025

(Date of Event Which Requires Filing of This Statement)

If the filing person has previously filed a statement on Schedule 13G to report the acquisition that is the subject of this Schedule 13D, and is filing this schedule because of §§ 240.13d-1(e), 240.13d-1(f) or 240.13d-1(g), check the following box.

The information required on the remainder of this cover page shall not be deemed to be "filed" for the purpose of Section 18 of the Securities Exchange Act of 1934 ("Act") or otherwise subject to the liabilities of that section of the Act but shall be subject to all other provisions of the Act (however, see the Notes).

SCHEDULE 13D

CUSIP No. 20459V105

1

Name of reporting person

Resolute Compo Holdings LLC

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

PF, OO

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

DELAWARE

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 49,290,409.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 49,290,409.00

11

Aggregate amount beneficially owned by each reporting person

49,290,409.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

41.0 %

14

Type of Reporting Person (See Instructions)

OO

Comment for Type of Reporting Person:

Consists of 49,290,409 shares of Class A Common Stock, $0.0001 par value per share, issued by CompoSecure, Inc. (the "Class A Common Stock"), held of record by Resolute Compo Holdings LLC ("Resolute Compo Holdings"). Row (13) is based upon 120,239,665 shares of Class A Common Stock that were outstanding as of August 27, 2025.

SCHEDULE 13D

CUSIP No. 20459V105

1

Name of reporting person

Tungsten 2024 LLC

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

PF

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

DELAWARE

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 49,937,302.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 49,937,302.00

11

Aggregate amount beneficially owned by each reporting person

49,937,302.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

41.5 %

14

Type of Reporting Person (See Instructions)

OO

Comment for Type of Reporting Person:

Consists of (i) 646,893 shares of Class A Common Stock held of record by Tungsten 2024 LLC ("Tungsten"), and (ii) 49,290,409 shares of Class A Common Stock held of record by Resolute Compo Holdings. Tungsten is the managing member of Resolute Compo Holdings, John Cote is the manager of Tungsten and Thomas Knott is a member of Resolute Compo Holdings. Tungsten, as managing member, has the right to vote and dispose of the shares of Class A Common Stock reported herein, subject to certain consultation rights held by Mr. Knott. Accordingly, Tungsten, Resolute Holdings, Mr. John Cote and Mr. Knott may each be deemed to share beneficial ownership of the shares of Class A Common Stock held of record by Resolute Compo Holdings, and Tungsten, Mr. John Cote and Mr. Knott may each be deemed to share beneficial ownership of the shares of Class A Common Stock held of record by Tungsten. Row (13) is based upon 120,239,665 shares of Class A Common Stock that were outstanding as of August 27, 2025.

SCHEDULE 13D

CUSIP No. 20459V105

1

Name of reporting person

Thomas R. Knott

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

OO

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

UNITED STATES

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 0.00
8	Shared Voting Power 49,937,302.00
9	Sole Dispositive Power 0.00
10	Shared Dispositive Power 49,937,302.00

11

Aggregate amount beneficially owned by each reporting person

49,937,302.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

41.5 %

14

Type of Reporting Person (See Instructions)

IN

Comment for Type of Reporting Person:

Consists of (i) 646,893 shares of Class A Common Stock held of record by Tungsten, and (ii) 49,290,409 shares of Class A Common Stock held of record by Resolute Compo Holdings. Tungsten is the managing member of Resolute Compo Holdings, John Cote is the manager of Tungsten and Thomas Knott is a member of Resolute Compo Holdings. Tungsten, as managing member, has the right to vote and dispose of the shares of Class A Common Stock reported herein, subject to certain consultation rights held by Mr. Knott. Accordingly, Tungsten, Resolute Holdings, Mr. John Cote and Mr. Knott may each be deemed to share beneficial ownership of the shares of Class A Common Stock held of record by Resolute Compo Holdings, and Tungsten, Mr. John Cote and Mr. Knott may each be deemed to share beneficial ownership of the shares of Class A Common Stock held of record by Tungsten. Row (13) is based upon 120,239,665 shares of Class A Common Stock that were outstanding as of August 27, 2025.

SCHEDULE 13D

CUSIP No. 20459V105

1

Name of reporting person

John D. Cote

2

Check the appropriate box if a member of a Group (See Instructions)

(a)
(b)

3

SEC use only

4

Source of funds (See Instructions)

OO

5

Check if disclosure of legal proceedings is required pursuant to Items 2(d) or 2(e)

6

Citizenship or place of organization

UNITED STATES

Number of Shares Beneficially Owned by Each Reporting Person With:

7	Sole Voting Power 1,500,000.00
8	Shared Voting Power 49,937,302.00
9	Sole Dispositive Power 1,500,000.00
10	Shared Dispositive Power 49,937,302.00

11

Aggregate amount beneficially owned by each reporting person

51,437,302.00

12

Check if the aggregate amount in Row (11) excludes certain shares (See Instructions)

13

Percent of class represented by amount in Row (11)

42.8 %

14

Type of Reporting Person (See Instructions)

IN

Comment for Type of Reporting Person:

Consists of (i) 646,893 shares of Class A Common Stock held of record by Tungsten, (ii) 49,290,409 shares of Class A Common Stock held of record by Resolute Compo Holdings and (iii) 1,500,000 shares of Class A Common Stock held by Ridge Valley LLC. Tungsten is the managing member of Resolute Compo Holdings, John Cote is the manager of Tungsten and Thomas Knott is a member of Resolute Compo Holdings. Tungsten, as managing member, has the right to vote and dispose of the shares of Class A Common Stock reported herein, subject to certain consultation rights held by Mr. Knott. Accordingly, Tungsten, Resolute Holdings, Mr. John Cote and Mr. Knott may each be deemed to share beneficial ownership of the shares of Class A Common Stock held of record by Resolute Compo Holdings, and Tungsten, Mr. John Cote and Mr. Knott may each be deemed to share beneficial ownership of the shares of Class A Common Stock held of record by Tungsten. Row (13) is based upon 120,239,665 shares of Class A Common Stock that were outstanding as of August 27, 2025.

SCHEDULE 13D

Item 1.	Security and Issuer
(a)	Title of Class of Securities: Class A Common Stock, $0.0001 Par Value per share
(b)	Name of Issuer: CompoSecure, Inc.
(c)	Address of Issuer's Principal Executive Offices: 309 Pierce Street, Somerset, NEW JERSEY , 08873.
Item 1 Comment: This Amendment No. 4 to Schedule 13D (this "Amendment No. 4") relates to the Class A Common Stock, par value $0.0001 per share (the "Class A Common Stock") of CompoSecure, Inc., a Delaware corporation (the "Issuer") and amends the initial statement on Schedule 13D filed by the Reporting Persons on September 19, 2024 (the "Initial Statement" and, as amended by those certain Amendment No. 1 filed on November 29, 2024, Amendment No. 2 filed on February 14, 2025, and Amendment No. 3 filed on August 22, 2025, and this Amendment No. 4, the "Schedule 13D"). Capitalized terms used but not defined herein shall have the meanings ascribed to them in the Initial Statement. This Amendment No. 4 is being filed to amend the Schedule 13D solely due to a change in the aggregate number of Class A Common Stock outstanding and not due to any transaction by the Reporting Persons.
Item 2.	Identity and Background
(a)	See Row (1) of each Reporting Person's cover page.
(b)	The principal business office of the Reporting Persons is 445 Park Avenue, Suite 5B, New York, NY 10022.
(c)	No change.
(d)	No change.
(e)	No change.
(f)	No change.
Item 3.	Source and Amount of Funds or Other Consideration
	Item 3 is hereby amended and supplemented as specified in Appendix A.
Item 5.	Interest in Securities of the Issuer
(a)	Item 5(a) is hereby amended and restated to read in its entirety as found in Appendix A.
(b)	Item 5(b) is hereby amended and restated to read in its entirety as found in Appendix A.
(c)	None.
(d)	None.
(e)	Not applicable.

SIGNATURE

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct.

Resolute Compo Holdings LLC

Signature:	/s/ John D. Cote
Name/Title:	John D. Cote, Manager of Tungsten 2024 LLC, its managing member
Date:	08/27/2025

Tungsten 2024 LLC

Signature:	/s/ John D. Cote
Name/Title:	Manager
Date:	08/27/2025

Thomas R. Knott

Signature:	/s/ Thomas R. Knott
Name/Title:	Thomas R. Knott
Date:	08/27/2025

John D. Cote

Signature:	/s/ John D. Cote
Name/Title:	John D. Cote
Date:	08/27/2025

FAQ

How many Class A shares of CompoSecure does Resolute Compo Holdings LLC report owning?

Resolute Compo Holdings LLC reports 49,290,409 shares of Class A Common Stock, representing 41.0% of the class based on 120,239,665 shares outstanding as of August 27, 2025.

What percent of CompoSecure Class A stock does John D. Cote beneficially own?

John D. Cote reports beneficial ownership of 51,437,302 shares, equal to 42.8% of the Class A Common Stock outstanding on the stated date.

Why was Amendment No. 4 filed for this Schedule 13D?

The amendment was filed solely due to a change in the aggregate number of Class A shares outstanding and not because of any transaction by the reporting persons.

Who has voting and dispositive authority over the reported shares?

Tungsten 2024 LLC, as managing member of Resolute Compo Holdings, has the right to vote and dispose of the reported shares, subject to consultation rights held by Thomas R. Knott.

On what share count are the percentage calculations based?

All percentage figures are based on 120,239,665 shares of Class A Common Stock outstanding as of August 27, 2025 as stated in the filing.