Advisory Business
A. General Description of Advisory Firm
11 Capital, a Delaware limited partnership formed in March 2019 and registered with the SEC
since January 2020, is an investment adviser to private fund clients and separately managed
accounts. 11 Capital has its principal place of business in New York, New York. Jason
McDougall (the “Chief Investment Officer”) is the principal owner of 11 Capital and has
ultimate responsibility for its management and investment decisions. 11 Capital Partners GP
LLC, a Delaware limited liability company, serves as the general partner of 11 Capital and is
owned by Mr. McDougall and Brian Fieber, the Chief Operating Officer and Chief Compliance
Officer (the “Chief Compliance Officer”) and/or entities owned or controlled by them or for the
benefit of them and their families.
11 Capital Fund GP LLC (the “Fund General Partner”), a Delaware limited liability company,
is an affiliate of 11 Capital and serves as the general partner of clients that are organized as U.S.
partnerships. 11 Capital and the Fund General Partner share facilities and personnel. The Fund
General Partner is owned by Mr. McDougall and Mr. Fieber and/or entities owned or controlled
by them or for the benefit of them and their families.
B. Description of Advisory Services
This Brochure generally includes information about 11 Capital and its relationships with their
clients. While much of this Brochure applies to all such clients, certain information included
herein applies to specific clients only.
11 Capital provides investment advisory services on a discretionary basis to the following private
fund clients (each a “Fund” and collectively, the “Funds”):
• 11 Capital Onshore Fund LP, a Delaware limited partnership (the “Domestic Fund”);
• 11 Capital Offshore Fund Ltd, an exempted company incorporated under the laws of the
Cayman Islands (the “Offshore Fund”); and
• 11 Capital Master Fund LP, a Cayman Islands exempted limited partnership (the “Master
Fund”), which serves as the master fund into which the Domestic Fund and the Offshore
Fund invest substantially all of their assets through a “master feeder” structure.
The Fund General Partner serves as the general partner of the Domestic Fund and the Master
Fund. The Offshore Fund is governed by its Board of Directors.
11 Capital also provides advisory services to separately managed accounts (the “Managed
Accounts”). The Managed Accounts pursue a substantially similar strategy to the Funds.
References throughout this document to “Clients” refer to the Funds and the Managed Accounts
listed above and to any other private investment funds and separately managed
accounts 11
Capital may advise in the future.
In providing advisory services, 11 Capital pursues a global long/short equity strategy focused on
identifying investments that fit into proprietary frameworks and conducting detailed company-
specific research through the use of its internal investment process. Please see “Item 8: Methods
of Analysis, Investment Strategies, and Risk of Loss” for a description of 11 Capital’s investment
strategies and certain related risks. Notwithstanding the foregoing, subject to any limitations in
the governing documents of the Clients, 11 Capital is not limited with respect to the types of
investment strategies it may employ or the markets or instruments in which it may invest.
The securities of the Funds are offered and sold on a private placement basis under exemptions
promulgated under the Securities Act of 1933, as amended, and other exemptions of similar
import under U.S. state laws and the laws of other jurisdictions where any offering may be made.
Investors in the Funds must meet the qualifications set forth in the applicable offering
documents. Persons reviewing this Brochure should not construe this as an offer to sell or
solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer
or solicitation will be made only by means of a confidential private placement memorandum.
C. Tailored Advisory Services for Client Accounts
11 Capital manages assets in accordance with the stated investment objectives of each Client, as
described in any relevant investment management agreement or similar agreement (an “IMA”)
or in an offering memorandum or a Client’s organizational documents (together with the IMA
and the offering memorandum, the “Offering Documents”). Investment advice is provided
directly to Clients and not individually to the limited partners, shareholders, and investors in
Clients (the “Investors”). In the case of the Managed Accounts, 11 Capital manages those assets
in accordance with the stated investment objectives of such Managed Accounts’ IMA. 11
Capital intends for the Funds and Managed Accounts to hold similar investments, to the extent
practical, subject to investment guidelines, tax, regulatory, and other considerations which may
cause investments to differ.
D. Wrap Fee Programs
11 Capital does not currently participate in wrap fee programs.
E. Assets Under Management
11 Capital manages, on a discretionary basis, approximately $353,996,000 of Client regulatory
assets under management. This figure for regulatory assets under management was determined
as of December 31, 2022. 11 Capital does not manage any assets on a non-discretionary basis.