AllBright Law Offices (Shenzhen) Legal Opinion on the 2026 Restricted Stock Incentive Plan (Draft) of Shenzhen Comixn High-Tech Co., Ltd.

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Table of Contents

Definitions 3

Main Text 4

I. Subject Qualifications of the Company to Implement this Incentive Plan 4

II. Legality and Compliance of the Contents of this Incentive Plan 5

III. Statutory Procedures Required for Implementing this Incentive Plan 11

IV. Information Disclosure of this Incentive Plan 12

V. Whether the Company Provides Financial Assistance to Incentive Participants 12

VI. Impact of this Incentive Plan on the Company and the Interests of All Shareholders 12

VII. Recusal of Interested Directors in Voting 13

VIII. Conclusion 13

Definitions

In this legal opinion, unless the context otherwise requires, the following terms have the meanings set forth below:

Main Text

To: Shenzhen Comixn High-Tech Co., Ltd.

AllBright Law Offices (Shenzhen) (hereinafter referred to as "this Firm") has been engaged by Shenzhen Comixn High-Tech Co., Ltd. (hereinafter referred to as the "Company") to issue this legal opinion regarding matters related to the Company's 2026 Restricted Stock Incentive Plan (hereinafter referred to as "this Incentive Plan").

To issue this legal opinion, this Firm hereby declares:

1. This Firm has issued legal opinions on important legal matters that occurred or existed prior to the date of this legal opinion and are related to this Incentive Plan within the scope stipulated by the "Administrative Measures on Equity Incentives of Listed Companies," and does not express opinions on non-legal matters such as finance, auditing, stock investment value, or the performance assessment standards of this Incentive Plan.

2. Where this legal opinion involves financial, auditing, or other content, this Firm has strictly cited professional documents issued by relevant parties (including but not limited to audit reports and internal control audit reports). However, such citation does not imply that this Firm makes any express or implied guarantee regarding the authenticity or accuracy of such professional documents and the cited content, nor does this Firm possess the professional qualifications to verify and judge such professional documents and cited content.

3. This legal opinion is issued based on Chinese law and is limited to Chinese laws that have been promulgated and are currently effective prior to the date of this legal opinion. This legal opinion does not express opinions on foreign laws or matters to which foreign laws apply.