9AT: WESTERLY CAPITAL MANAGEMENT LLC

other names

WESTERLY CAPITAL MANAGEMENT LLC

Adviser Profile

As of Date	03/31/2026
Registration	SEC, Approved, 07/29/2022
Other registrations (2)	SEC, ERA - Withdrawn, 06/30/2022 California, ERA - Withdrawn, 06/30/2022
Former registrations	WESTERLY CAPITAL MANAGEMENT LLC
ADV Location	SAN FRANCISCO, CA, United States
Contact Info	415 xxxxxxx
Websites

AUM^*	488,905,268 102%
of that, discretionary	488,905,268 102%
Private Fund GAV^*	488,905,268 70%
Avg Account Size	162,968,423 34%
SMA’s	No
Private Funds	3 1

Adviser Type

- Large advisory firm

Number of Employees 3

of those in investment advisory functions 2

Client Types

- Pooled investment vehicles

Advisory Activities

- Portfolio management for pooled investment vehicles

Compensation Arrangments

- A percentage of assets under your management
- Performance-based fees

SEC Fund Type	Count	GAV
Fund TypeHedge Fund	Count3	GAV$488,905,268

Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser PORTLAND HILL ASSET MANAGEMENT LIMITED	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM158.5m	#Funds-
Adviser TERRA PARTNERS ASSET MANAGEMENT	Hedge Fund266.9m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV266.9m	AUM266.9m	#Funds3
Adviser ALVENTO CAPITAL PARTNERS LLP	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM202.3m	#Funds-
Adviser URSA FUND MANAGEMENT LLC	Hedge Fund1.2b	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV1.2b	AUM1.2b	#Funds1
Adviser OAKCLIFF PARTNERS LLC	Hedge Fund356.3m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV356.3m	AUM356.3m	#Funds2
Adviser BRIZO CAPITAL, LP	Hedge Fund176.1m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV176.1m	AUM294.5m	#Funds1
Adviser QUANTITATIVE VALUE TECHNOLOGIES	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM172.6m	#Funds-
Adviser BARCA CAPITAL, LLC	Hedge Fund394.8m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV394.8m	AUM439.0m	#Funds2
Adviser SMP ASSET MANAGEMENT, LLC	Hedge Fund255.4m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV255.4m	AUM255.4m	#Funds1
Adviser WINDSAIL CAPITAL GROUP, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM196.3m	#Funds-

Stock Ticker	Stock Name	$ Position	% Position	$ Change	# Change
Stck Ticker46090E953	Stock NameINVESCO QQQ TR (PUT)	$ Position$43,288,500	% Position12.00%	$ Change-65.00%	# Change-63.00%
Stck Ticker573874104	Stock NameMARVELL TECHNOLOGY INC	$ Position$19,810,000	% Position5.00%	$ Change17.00%	# Change0.00%
Stck Ticker444144109	Stock NameHUDSON TECHNOLOGIES INC	$ Position$18,669,000	% Position5.00%	$ Change7.00%	# Change25.00%
Stck Ticker902685106	Stock NameUDEMY INC	$ Position$19,866,000	% Position5.00%	$ Change-15.00%	# Change8.00%
Stck Ticker17275R102	Stock NameCISCO SYS INC	$ Position$17,457,750	% Position5.00%	$ Change	# Change
Stck Ticker29355A107	Stock NameENPHASE ENERGY INC	$ Position$15,124,000	% Position4.00%	$ Change170.00%	# Change129.00%
Stck Ticker925550105	Stock NameVIAVI SOLUTIONS INC	$ Position$14,144,000	% Position4.00%	$ Change-31.00%	# Change-63.00%
Stck Ticker654902204	Stock NameNOKIA CORP	$ Position$14,472,000	% Position4.00%	$ Change66.00%	# Change33.00%
Stck Ticker550241103	Stock NameLUMEN TECHNOLOGIES INC	$ Position$15,290,000	% Position4.00%	$ Change146.00%	# Change175.00%
Stck Ticker358054104	Stock NameFRESHWORKS INC	$ Position$15,257,000	% Position4.00%	$ Change19.00%	# Change81.00%

Brochure Summary

Overview

Westerly Capital Management LLC (the “Adviser”) is a limited liability company formed in Delaware in 2006. The Adviser is primarily owned by Christopher J. Galvin and has an office in San Francisco, CA. Westerly Capital Management LLC has been registered with the SEC since July 2022. The Adviser was previously operating and reporting to the SEC as an Exempt Reporting Adviser since April 2012. The Adviser continues to manage the following pooled investment vehicles: Westerly Partners QP, L.P, a Delaware limited partnership (“Westerly QP”).; and Westerly Partners, L.P., a Delaware limited partnership (“Westerly Partners”). Westerly QP and Westerly Partners are collectively referred to as the “Clients” or the “Funds”. Westerly Holdings LLC serves as the general partner to the Clients (the “General Partner”). The Adviser provides discretionary investment advice to the Clients. The Funds’ investment objective is to achieve absolute performance in primarily the small to mid-cap technology and growth sectors through stock selection matched with adherence to strict risk management principles. Neither the LPA nor the investment management agreements

impose any limits on the types of securities or other instruments in which the Funds may invest, the types of positions it may take, the concentration of its investment by sector, industry, fund, country, class or otherwise, the amount of leverage it may employ or the number or nature of short positions it may take. Further, depending on conditions and trends in securities markets, the Funds may pursue strategies and/or employ techniques other than those described above, to the extent the Adviser considers doing so appropriate and in the Funds’ best interests. The Adviser’s investment decisions and advice with respect to the Clients are subject to each Client’s investment objectives and guidelines, as set for in its respective “Offering Documents” which include each Client’s subscription documents, Limited Partnership Agreements (“LPA”), and other legal documents set in place when an investor decides to invest in the Adviser’s Funds. The Adviser does not participate in wrap fee programs. As of December 31, 2023, the Adviser had approximately $242.5M of regulatory assets under management, all of which is managed on a discretionary basis.

WESTERLY CAPITAL MANAGEMENT LLC

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