ADVISORY BUSINESS A. General Description of Advisory Firm 1. Pantera Advisors LLC Pantera Advisors LLC (the “Investment Adviser”, “we” and “us”), is a Delaware limited liability company that was formed in 2004. We have three offices, which are located in (i) Menlo Park, California, (ii) San Juan, Puerto Rico and (iii) New York, New York. Our principal office and place of business is in Menlo Park. The New York office primarily houses investor relations and infrastructure support personnel. We are controlled by our principal owner, Daniel Morehead (the “Principal Owner”), who is the managing member of the Investment Adviser. 2. Pantera Capital Management Puerto Rico LP Pantera Capital Management Puerto Rico LP (the “Puerto Rico Relying Adviser”), is a Delaware limited partnership that was formed in 2021. It has one office, which is located in Puerto Rico. The Relying Adviser is controlled by its general partner, Pantera GP Puerto Rico LLC, which is wholly owned by the Principal Owner. The Relying Adviser is registered with the SEC as an investment adviser. 3. Pantera Capital Management LP Pantera Capital Management LP (collectively with the Puerto Rico Relying Adviser, the “Relying Advisers”), is a Delaware limited partnership that was formed in 2004. Pantera Capital Management LP is controlled by its general partner, Pantera GP LLC, which is wholly controlled by the Principal Owner. Pantera Capital Management LP is registered with the SEC as an investment adviser. 4. Fund General Partner Entities Our registration on Form ADV also covers Pantera Venture GP LLC (the “Venture General Partner”), Pantera Venture II GP LLC (the “Venture II General Partner”), Pantera Venture III GP LLC (the “Venture III General Partner”), Pantera Bitcoin Management LLC (the “Bitcoin Manager”), Pantera Blockchain GP LLC (the “Blockchain General Partner”) and Pantera Liquid and Early-Stage Token GP LLC (the “Liquid and Early-Stage Token General Partner”, collectively with the Bitcoin Manager, the Venture General Partner, the Venture II General Partner and the Venture III General Partner, the “Fund General Partners”), which are all limited liability companies organized under the laws of the state of Delaware. The Fund General Partners are affiliates of the Investment Adviser and serve or may serve as the general partner of Funds (as defined below) that are U.S. or offshore partnerships. The Fund General Partners’ facilities and personnel are provided by the Investment Adviser. The Principal Owner is the principal owner and the managing member of, and controls, the Fund General Partners. B. Description of Advisory Services This Brochure generally includes information about us and our relationships with our clients and affiliates. While much of this Brochure applies to all such clients and affiliates, certain information included herein applies to specific clients or affiliates only. 1. Advisory Services We serve as the investment adviser, with discretionary trading authority, to private pooled investment vehicles, the securities of which are offered to investors on a private placement basis (each, a “Fund” and collectively, the “Funds”). Our “clients” are discussed herein. The Funds include:
• Pantera Venture Fund LP, a Delaware limited partnership (the “Venture I Fund”);
• Pantera Venture Fund II LP, a Delaware limited partnership (the “Venture II Fund”),
• Pantera Venture Fund III LP, a Delaware limited partnership (the “Venture III Fund”);
• Pantera Venture Fund III A LP, a Delaware limited partnership (the “Venture III A Fund”);
• Pantera Venture Offshore Fund III LP, a Cayman Islands exempted limited partnership (the “Venture III Offshore Fund”, and together with the Venture I Fund, the Venture II Fund, the Venture III Fund and the Venture III A Fund, the “Venture Funds”);
• Pantera Early-Stage Token Fund Ltd, a Cayman Islands exempted company (the “Early-Stage Token Offshore Fund”);
• Pantera Early Stage Token Master Fund LP, a Cayman Islands exempted limited partnership (the “Early Stage Token Master Fund”, and together with the Early-Stage Token Offshore Fund, the “Early-Stage Token Offshore Funds”);
• Pantera Early-Stage Token Fund LP, a Delaware limited partnership (the “Early-Stage Token Fund I”);
• Pantera Early-Stage Token Fund II LP, a Delaware limited partnership (the “Early- Stage Token Fund II”, and together with the Early-Stage Token Fund I, the “Early- Stage Token Funds”);
• Pantera Bitcoin Feeder Fund Ltd., a Cayman Islands exempted company (the “Bitcoin Feeder Fund”);
• Pantera Bitcoin Fund Ltd., a Cayman Islands exempted company (the “Bitcoin Fund”, and together with the Bitcoin Feeder Fund, the “Bitcoin Funds”);
• Pantera Liquid Token Fund LP, a Delaware limited partnership (the “Liquid Token Fund”);
• Pantera Liquid Token Offshore Fund Ltd, a Cayman Islands exempted company (the “Liquid Token Offshore Fund”);
• Pantera Liquid Token Offshore Master Fund LP, a Cayman Islands exempted limited partnership (the “Liquid Token Master Fund”, and together with the Liquid Token Fund, and the Liquid Token Offshore Fund, the “Liquid Token Funds”);
• Pantera Blockchain Fund LP, a Delaware limited partnership (the “Blockchain Fund”);
• Pantera Blockchain Venture Fund LP, a Delaware limited partnership (the “Blockchain Venture Fund”); and
• Pantera Blockchain Offshore Fund LP, a Cayman Islands exempted limited partnership (the “Blockchain Offshore Fund”, and together with the Blockchain Fund, the “Blockchain Funds”). The Venture General Partner serves as the general partner of the Venture I Fund, the Venture II General Partner serves as the general partner of the Venture II Fund, the Venture III General Partner serves as the general partner of the Venture III Fund, the Venture III A Fund and the Venture III Offshore Fund, and the Liquid Token General Partner serves as the general partner of the Liquid Token Funds, and the Early-Stage Token Funds. The Bitcoin Manager serves as investment manager to the Bitcoin Funds. The Pantera Blockchain GP LLC serves as the General Partner to the Blockchain Funds. The Pantera Blockchain Venture GP LLC serves as the General Partner to the Blockchain Venture Fund. 2. Investment Strategies and Types of Investments We have included below summaries of the investment strategies for all of our clients. Please see Item 8 for additional information. (a) Venture Funds The Venture Funds pursue venture capital investments in businesses that seek to

use blockchain technology and other less-liquid investments (excluding Early-Stage Token Offerings and Digital Assets) (“Blockchain Venture Assets”). The Investment Adviser seeks to capitalize on the highly disruptive migration Pantera believes is about to occur, from existing ledger systems and communication channels that rely on centralized third-party trust, to blockchain technology that will allow peer-to-peer (enterprises and individuals) connection across myriad industries and geographies to directly transfer information and value. The Venture Funds generally plan to lead seed and Series A deals, taking board seats where appropriate. The Investment Adviser expects to have access to superior deal flow, by virtue of its active presence in the blockchain industry. The Venture Funds will seek to build a diversified portfolio to balance risk. Certain Venture Funds may, from time to time, hold tokens through early-stage token offerings (“Early-Stage Token Offerings”) that potentially convert into equity where the applicable Venture Fund invests in the underlying issuing company. Such Venture Funds will also be open to ancillary spaces, such as fintech, artificial intelligence, and machine learning. (b) Early-Stage Token Funds The investment objective of the Early-Stage Token Funds is to achieve capital appreciation and maximize absolute returns by participating in early-stage token opportunities within the blockchain space, with the ultimate goal of holding Liquid Tokens (defined below) resulting from such opportunities. The Early-Stage Token Funds seek to secure Liquid Tokens and access to Liquid Tokens using a wide variety of means and arrangements. In prior years, early-stage token opportunities arose primarily from new tokens, blockchain protocols or related services, financed and launched through Early-Stage Token Offerings of digital assets, virtual currencies, cryptocurrencies and/or other coins and tokens expected to have acceptable liquidity characteristics (collectively “Liquid Tokens”). Today, as the landscape for early-stage token opportunities is evolving, the Investment Adviser is adapting to market practices and novel ways of obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, Simple Agreements for Future Equity (“SAFEs”), warrants for tokens and purchase agreements for existing Liquid Tokens. (c) Early-Stage Token Offshore Funds The investment objective of the Early-Stage Token Offshore Funds is to achieve capital appreciation and maximize absolute returns by participating in Early-Stage Token Offerings of Liquid Tokens. The Investment Manager will rely on various approaches to obtaining Liquid Tokens and the rights to Liquid Tokens, including in connection with or through preferred equity stakes in portfolio companies, SAFEs, warrants for tokens and purchase agreements for existing Liquid Tokens. The Early-Stage Token Offshore Funds generally intend to hold each investment for long-term appreciation over a period of not less than 12 months. (d) Bitcoin Funds The investment objective of the Bitcoin Funds is to invest substantially all of its assets in Bitcoin. The Investment Adviser will only cause the Bitcoin Funds to sell Bitcoin to fund redemptions and pay expenses and liabilities. The Bitcoin Funds will not trade, buy, sell or hold Bitcoin derivatives for any purpose. Transactions in Bitcoin will not be made on a leveraged, margined, or offer-financed basis. The Bitcoin Funds may engage in Bitcoin lending transactions, in the sole discretion of the Bitcoin Manager. (e) Liquid Token Funds The investment objective of the Liquid Token Funds is to achieve capital appreciation and maximize absolute returns by investing in a diversified portfolio of digital assets, virtual currencies, cryptocurrencies and/or other liquid coins and tokens. The Liquid Token Fund does not (i) expect to participate in Early-Stage Token Offerings (because the Fund invests solely in actively traded Liquid Tokens), or (ii) intend to invest in Liquid Token that are securities for purposes of U.S. laws and regulations. (f) Blockchain Funds and Blockchain Venture Fund The investment objective of the Blockchain Funds is to offer investors the opportunity to make a single allocation and receive professionally-managed exposure to multiple facets of the emerging blockchain and cryptocurrency markets. The Blockchain Funds will invest in (i) venture capital investments in blockchain assets (including Early-Stage Token Offerings that are not Digital Assets) (collectively, “Blockchain Venture Assets”) and (ii) Digital Assets. The investment objective of the Blockchain Venture Fund is substantially similar to the investment objective of a certain class of interests of the Blockchain Fund. The descriptions set forth in this Brochure of specific advisory services that we offer to our clients, and investment strategies pursued and investments made by us on behalf of our clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each client’s investment objectives and guidelines. The investment strategies we pursue are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any client will be achieved. (g) Other Clients The Investment Adviser serves as investment manager with discretionary authority with respect to a separately managed account that is beneficially owned by a private fund sponsored by a third party (the “Managed Account”). The investment strategies applicable to such clients are detailed in those clients’ governing documents. C. Availability of Customized Services for Individual Clients Our investment decisions and advice with respect to each Fund will be subject to each Fund’s investment objectives and guidelines, as set forth in its respective offering documents. D. Wrap Fee Programs We do not currently participate in any Wrap Fee Programs. E. Assets Under Management We manage, on a discretionary basis, approximately $3,973,880,060 of client assets, determined as of December 31, 2022, calculated on the basis of regulatory assets under management. We do not manage any assets on a non-discretionary basis. In calculating the regulatory assets under management identified herein, the amounts attributable to the Venture Funds reflect valuations as of September 30, 2022, the last quarter-end date for which valuation figures are currently available.