A. Gruenstein Investments LLC (the “Firm”) was established in 2018 as a Delaware limited
liability company managed by David Gruenstein (the “Principal”). The Firm is controlled and
owned by the Principal.
The Principal spent more than 35 years practicing law at Wachtell, Lipton, Rosen & Katz. He
handled a broad variety of complex civil litigation and regulatory enforcement matters, giving
counsel to numerous corporate clients (including investment advisers). The Principal received an
A.B. from Columbia College in 1977, with a major in probability and statistics, and subsequently
a J.D. from Harvard Law School in 1980. His legal career has included working on a variety of
complex issues including those with a quantitative aspect, for example, constructing (and
deconstructing an adversary’s) complex damage or other expert analysis, and analyzing trading
activity and markets. Since leaving Wachtell Lipton in January 2017, and prior to commencing the
advisory business of the Firm, the Principal served as Senior Advisor to Steinberg Asset
Management LLC (“Steinberg”).
The Principal remains a member of the New York legal bar, but is not currently and does not intend
in the future to practice law generally or in connection with the Firm or its business.
B. The Firm provides its investment advisory services to both a private fund client and to various
managed account clients. The Firm’s private fund client is Gruenstein Partners LP, a Delaware
limited partnership (the “Fund”), which invests primarily in the common stock or American
Depository Receipts (“ADRs”) of publicly-traded companies in the U.S. and other developed
countries. The Fund may invest in other securities, as determined by the Firm, including for example
options, fixed income securities, and money market instruments. The Fund may at times as part of
its strategy hold a significant portion of its assets in cash, money market instruments, and other
short-term high quality investments. The Fund offers its limited partner interests only on a private
placement basis exempt from the registration requirements of the U.S. Securities Act of 1933, as
amended (the “1933 Act”), pursuant to its confidential private placement memorandum, as
supplemented from time to time (the “PPM”), and limited partnership agreement, as amended from
time to time (the “LPA”). The Firm will have discretionary authority over the assets of the Fund.
Offers to invest
in the Fund will be made only by the Fund’s PPM and LPA. This document is not
an offer to sell or a solicitation of offers to buy any limited partner interests or other securities of
the Fund. Full information on the investment strategy, fees, expenses, risks, and potential conflicts
of interest of the Fund are set forth in the PPM and LPA.
In addition, the Firm advises various managed accounts, to which the Firm provides wealth
management advice and other advisory services to individuals and entities (collectively, “Managed
Accounts”). The Firm may provide advisory services to Managed Accounts on both a discretionary
and a non-discretionary basis. Managed Account clients will include both tax-exempt investors, such
as retirement accounts, and investors subject to income tax, such as individuals who may be
accredited persons. The Firm’s Managed Account clients include, for example, (a) members
of the Principal’s family (which may include trusts and estate planning vehicles formed by members
of the Principal’s family), and (b) other individuals and entities with historical relationships with
the Principal (investors described in (a) and (b) are referred to as “Friends & Family” investors).
C. The Firm tailors its advisory services to the Fund in accordance with the Fund’s investment
objective and strategy as disclosed in the PPM. The Firm also tailors its wealth management advice
and other services that the Firm provides for Managed Accounts to individual circumstances
including the taxable or non-taxable nature of the client, client goals and risk tolerances, and the
needs of the client for, among other things, cash flow and stability in the portfolio. The Firm in the
past has offered and in the future may offer a Managed Account investing in a single security for
which it has a performance fee arrangement. Managed Account clients may impose restrictions on
investing in specified securities or types of securities, as mutually agreed with the Firm. The Firm
does not, however, tailor its advisory services to the individual needs or any specified investment
mandates of the investors in the Fund and those investors may not impose restrictions on investing
in certain securities or types of securities.
D. The Firm does not participate in any wrap fee programs.
E. As of December 31, 2023, the Firm has $50,155,225 of regulatory assets under management, of
which $47,778,813 are managed on a discretionary basis and $2,376,412 are managed on a non-
discretionary basis.