FIRM DESCRIPTION
Alta Fox Capital Management, LLC (“Alta Fox”), a Texas limited liability company, was formed in 2018. Alta Fox
currently provides investment management and other services solely with respect to affiliated private pooled
investment vehicles, Alta Fox Opportunities Fund, LP (“the Fund”) and one special purpose vehicle (“SPV”),
collectively “the Funds.” The SPV holds a single asset. Alta Fox has full discretionary authority with respect to the
investment decisions of the Funds. Our investment advisory services are provided in accordance with the investment
objectives and guidelines set forth in the Fund offering and governing documents. The information set forth in this
brochure is qualified in its entirety by each Fund’s offering and governing documents.
Alta Fox is registered as an investment adviser with the SEC under the Investment Advisers Act of 1940, as amended
(the “Advisers Act”), and one of our affiliates, Alta Fox GenPar, LP, is the general partner of the Funds (the “General
Partner”). See Item 10: Other Financial Industry Activities and Affiliations. Except as the context otherwise
requires, any references to “Alta Fox” or “our” in this brochure includes Alta Fox and the General Partner.
PRINCIPAL OWNER
The Managing Member of Alta Fox and control person of the General Partner is Patrick Connor Haley.
TYPES OF ADVISORY SERVICES
Alta Fox serves as investment manager to the Funds and is responsible for investing and re-investing the capital of the
Fund in securities, financial instruments and/or other assets in accordance with the investment objectives, policies and
guidelines set forth in each Fund’s offering and governing documents. See Item 8: Methods of Analysis, Investment
Strategies and Risk of Loss.
The SPV holds a single asset. The asset held in the current and in any future SPV may also be a company in which
the Alta Fox Opportunities Fund is also invested. To mitigate this conflict
of interest between an SPV and the Fund,
Alta Fox follows its trade allocation policy which mandates that when multiple Alta Fox managed Funds buy or sell
the same security on the same day, Alta Fox aggregates and allocates trades on a pro rata basis or according to a
documented pre-trade allocation order approved by the Chief Compliance Officer. If a trade in a security that is held
by multiple Funds is not executed for all the Funds, the Chief Compliance Officer must approve the transaction prior
to execution and document the rationale for such transaction(s).
INVESTMENT RESTRICTIONS
Alta Fox provides investment advice to the Funds in accordance with the investment objectives, policies and guidelines
set forth in each Fund’s offering and governing documents, and not in accordance with the individual needs or
objectives of any particular investor in the Funds. Investors generally are not permitted to impose restrictions on
investments in certain securities or types of securities or limitations on the management of the Funds. Notwithstanding
the foregoing, Alta Fox has, and may in the future, enter into side letter agreements or similar arrangements with
certain investors that have the effect of establishing rights under, or altering, modifying, waiving, or supplementing
the terms of, the governing documents of a Fund in respect of such investors. Among other things, side letter
agreements may entitle an investor in a Fund to lower fees, information or transparency rights, most favored nations
status, investment capacity rights, notification rights, rights, or terms necessary or advisable in light of particular legal,
regulatory, or policy considerations of or related to an investor, and/or other preferential rights and terms.
ASSETS UNDER MANAGEMENT
As of December 31, 2023, Alta Fox had approximately $413 million in regulatory assets under management. All of
these assets are managed on a discretionary basis.