Overview
ADVISORY BUSINESS
A. Description of Advisory Firm
Gravity Capital Management, LLC (also referred to as the “Firm”, “GCM” or the
“Adviser”) was founded in 2003 by Adam Seessel. Mr. Seessel is the current principal and sole
owner of GCM. GCM is organized as a limited liability company in the State of Delaware.
GCM conducts investment advisory activities in separately managed accounts (“SMAs”).
GCM expects to invest in mainly long positions in publicly traded equity securities in U.S. and
non-U.S. issuers. In certain circumstances, investments in short positions and options on financial
indices and individual securities may be used to hedge investments in the SMAs.
GCM also operates the Gravity Long‐Biased Fund, LP (“the Fund”) as a concentrated,
value-oriented portfolio. The Fund seeks long-term capital appreciation by investing its assets
primarily in equity securities. From time to time in executing this strategy, the Firm may use leverage.
GCM expects that the Fund will invest primarily in common stocks, but is permitted, pursuant to
the Fund’s investment management agreement and offering and governing documents, to use cash
and/or short positions in equities and equity exchange-traded funds (“ETFs”). The Fund will invest
primarily in the securities of U.S. companies, but GCM will also invest in companies outside of
the U.S., as necessary, in meeting
the Fund’s investment mandate.
B. Description of Advisory Services
GCM provides day-to-day portfolio management services and has discretion to purchase
and sell securities for the Fund and the SMAs (each of the Fund and the SMAs, a “Client” and
collectively, the “Clients”).
The Fund and the SMAs expect to be invested in primarily publicly traded equity securities
of public issuers. In certain circumstances, investments in options on financial indices and
individual securities may be used to establish or increase long or short positions or to hedge the
Clients’ investments.
While GCM expects to invest primarily in domestic equity securities, GCM is not limited
in the type of investments used to achieve the Clients’ investment mandates.
C. Availability of Customized Services for Individual Clients
The Clients are generally managed in accordance with GCM’s investment mandate with its
Clients and are not tailored to any particular investor. While it is discouraged, SMAs may formally
request to impose certain restrictions relating to their investment.
D. Wrap Fee Programs
GCM does not participate in a wrap fee program.
E. Assets Under Management
As of December 31, 2023, GCM manages a total of $67,891,887 in regulatory assets under
management. GCM manages $65,248,551 on a discretionary basis and $2,643,336 on a non-
discretionary basis.
~ 5 ~