Adviser Profile

As of Date:

03/25/2024

Adviser Type:

- Large advisory firm

Number of Employees:

of those in investment advisory functions:

Registration:

SEC, Approved, 7/29/2022

Other registrations (2)

Former registrations

WESTERLY CAPITAL MANAGEMENT LLC

AUM:

242,485,946 18.51%

of that, discretionary:

242,485,946 18.51%

GAV:

242,485,946 18.51%

Avg Account Size:

121,242,973 18.51%

SMA’s:

Private Funds:

Contact Info

415 xxxxxxx

Websites :

Client Types:

+

Advisory Activities:

+

Compensation Arrangments:

+

Reported AUM

Discretionary

Non-discretionary

205M 175M 146M 117M 88M 58M 29M

2023

Recent News

Pie Radar GAV Count

Private Funds Structure

Fund Type	Count	GAV
Hedge Fund	2	$242,485,946

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Private Funds

GAV Count

Employees

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, 2022, the Adviser had approximately $204.6M of regulatory assets under management, all of which is managed on a discretionary basis.