A. Creighton AI is a Delaware limited liability company that was formed on December 6, 2004 and is principally owned by Artificial Intelligence Holdings LLC, a company majority owned by James Creighton, the Firm’s Chief Investment Officer. Any references to the “Firm”, “us,” “we,” and “our” in this Brochure refer to Creighton AI. Any defined terms used in this Brochure not otherwise defined herein, have the definition ascribed to them in the offering documents of the applicable Fund (as defined below). B. Creighton AI offers investment advisory services to its clients on a discretionary basis, including private funds organized as domestic or foreign private pooled investment vehicles, some of which invest all or substantially all of their investible assets in other vehicles in a master feeder structure or pooled investment vehicle advised or sub-advised by Creighton AI. Creighton AI’s current private fund clients include the Creighton AI Fund LP (the “the Master Fund”), and the Creighton AI Fund (Cayman), LTD (the “Feeder Fund” and together with the Master Fund the “Fund”). Creighton AI may advise additional pooled investment vehicles and additional clients in the future. Creighton AI offers sub-advisory investment management services to institutional clients in the form of separately managed accounts, sub-advised, pooled investment vehicles, or similar arrangements based on the objectives of the client. Creighton AI will enter into an agreement with the primary adviser to provide investment management services to such clients “Sub-Advisory Clients.” Under such sub-advisory arrangement, the primary adviser remains responsible for determining the Sub- Advisory Clients’ investment objectives and whether Creighton AI’s investment strategy programs are suitable to meet such investment objectives. Creighton AI is responsible for the discretionary management of the assets as designed to achieve investment objectives as set forth in applicable contractual arrangement with each Sub-Advisory Client. The Fund together with each Sub-Advisory Client shall be referred to herein where applicable as a “Client” or the “Clients.” Creighton AI employs proprietary algorithms that identify expected returns for each security within its defined investment universe.

Creighton AI specializes in using proprietary machine learning and statistical modeling techniques to drive client investment strategies. All discussions of the Fund and Sub-Advisory Clients in this brochure, including but not limited to their investments, the strategies used in managing the Fund and Sub-Advisory Clients, the fees and other costs associated with an investment in the Fund and Sub-Advisory Clients, and conflicts of interest faced by the Firm in connection with management of the Fund and Sub-Advisory Clients, are qualified in their entirety by reference to each Fund’s respective offering memorandum, advisory agreement, and applicable Sub-Advisory Clients’ contractual agreements. C. Creighton AI tailors its investment advisory services to the objectives, strategies, restrictions, guidelines and conditions set forth in each Fund’s respective private placement memorandum and investment management agreements and does not tailor investment decisions to any particular investor therein. In accordance with common industry practice, the Firm may enter into side letters and other agreements and arrangements with certain investors pursuant to which they may agree to vary certain of the terms applicable to any such investors or grant to any such investors specific rights, benefits, or privileges that are not made available to investors personally. Such side letters may provide terms and conditions that are more advantageous than those set forth in the applicable Fund’s offering documents. Such terms and conditions may include without limitation special rights Creighton Capital Management: Part 2A Page 5 to make future investments, preferred fee structures, different transparency rights, reporting rights, different withdrawal/redemption rights and/or such other rights negotiated between Creighton AI and investors in the Fund. Fees referenced within this Brochure may vary from an investors’ actual fees based on rates separately negotiated on an individual investor basis. D. Creighton AI does not participate in any wrap fee programs. E. As of December 31, 2022, the amount of regulatory assets under management managed by Creighton AI totaled: $302,782,997. We do not offer non-discretionary investment management services.