THE OFFICE OF DEFECTS INVESTIGATION (ODI) PRODUCED AN INFORMATION REQUEST (IR) LETTER DATED OCTOBER 14, 2004 WHICH DEFINED THE SUBJECT VEHICLES AS MODEL YEAR 1999 - 2001 HONDA ACCORD VEHICLES WHICH WERE NOT WITHIN THE SCOPE OF PRIOR RECALL ACTION (03V423) HONDA CONDUCTED TO RESOLVE AN INTERLOCK DEFECT.HONDA SUBMITTED RESPONSES ON NOVEMBER 29 AND DECEMBER 21, 2004.THE FAILURE REPORTS NOTED ABOVE HAVE BEEN DETERMINED FROM ODI'S ANALYSIS OF NHTSA'S COMPLAINT DATABASE AND AN INITIAL ANALYSIS OF THE MANUFACTURER'S IR RESPONSE DATA (FURTHER ANALYSIS REQUIRED).SOME OF THE HONDA REPORTS ARE DUPLICATIVE OF ODI.TAKING INTO ACCOUNT A SHORTER SERVICE LIFE, THE FAILURE INCIDENCE OF THE SUBJECT VEHICLES IS SIMILAR TO THAT DETERMINED WHEN ODI CONDUCTED PRELIMINARY EVALUATION (PE) 03-013, WHICH INVOLVED INTERLOCK FAILURES ON OLDER ACCORDS SUBSEQUENTLY RECALLED UNDER THE 03V423 ACTION.ACCORDINGLY, THE PETITON IS GRANTED AND ODI HAS OPENED PE05-002 TO FURTHER INVESTIGATE THE MATTER.