Overview
A. Description of Advisory Firm
Strategy Capital LLC (the “Manager” or “Strategy Capital”) is a Delaware limited liability company
founded in 2002 and is now registered with the SEC. Strategy Capital is owned by Hamilton Helmer,
Managing Member, and John Rutherford, Special Member, Chief Compliance Officer, and Chief
Operating Officer.
Strategy Capital GP LLC (“General Partner”), a Delaware limited liability company founded in 2014, is
affiliated with Manager and is owned by Hamilton Helmer, Managing Member and John Rutherford,
Special Member, Chief Compliance Officer, and Chief Operating Officer.
B. Description of Advisory Services
Strategy Capital currently provides investment advice and management services through the following
types of products (each a “Client” and collectively, the “Clients”): (i) two privately placed investment
funds structured as limited partnerships for which Strategy Capital is the investment manager, one
established in 2013 (the “2013 Partnership”) and one established in 2019 (the “2019 Partnership”)(each
a “Partnership” and collectively, the “Partnerships”); (ii) an investment company registered under the
Investment Company Act of 1940 sponsored by advisers unaffiliated with Strategy Capital for which the
Manager acts as sub-adviser (the “Sub Advised Account”); (iii) a separate account (the “Endowment
SMA”); and (iv) a special purpose vehicle entity formed as a limited liability company
(“SPV”) for which
Strategy Capital is the managing member. As a practical matter, the SPV was created to facilitate an
investment in a private company on behalf of a limited number of Investors.
Investment advisory services are provided to each Client pursuant to separate investment management or
sub advisory agreement between each Client and Strategy Capital (for each client the “Constituent
Documents”).
Strategy Capital’s investment objective is to achieve long-term capital appreciation through investments
in individual publicly traded equity securities. Current income is not an objective. Strategy Capital’s
strategies and the risks involved are described in response to Item 8, below.
Each Partnership conducts a private offering of its partnership interests (“Interests”) to certain qualified
investors as described in response to Item 7, below (referred to herein as “Investors”).
C. Client Tailored Services and Client Imposed Restrictions
Advisory services are tailored to achieve the Clients’ investment objectives. Generally, Strategy Capital
has the authority to select which and how many securities and other instruments to buy or sell without
consultation with the Clients or their Investors.
D. Wrap Fee Programs
Strategy Capital does not participate in or offer wrap fee programs.
E. Assets Under Management
As of December 31, 2022, Strategy Capital had regulatory assets under management on a discretionary
basis of $509,387,000.