Advisory Business
A. General Description of Advisory Firm
Niles Investment Management, LLC (“NIM”, the “Firm”, “we”, “us”, and similar terms), a
Delaware limited liability company formed in November 2023 and owned by Daniel and Jennifer
Niles, began operations as an investment manager to private fund clients on April 1, 2024. The
Firm maintains its principal place of business in Florida. The Firm is controlled by its managing
member, Daniel Niles (the “Managing Member”).
The Firm’s registration on Form ADV also covers SF GP I, LLC, a Delaware limited liability
company (the “Fund I General Partner”), and SF GP II, LLC, a Delaware limited liability
company (the “Fund II General Partner,” and together with the Fund I General Partner, the
“Funds’ General Partners”). The Funds’ General Partners are affiliates of the Firm and serve as
the general partners of the private fund clients that are organized as U.S. limited partnerships and
Cayman Islands exempted companies. The Firm and the Funds’ General Partners share facilities
and personnel. The Managing Member is the managing member of each of the Funds’ General
Partners.
B. Description of Advisory Services
This Brochure generally includes information about us and our relationships with our clients.
While much of this Brochure applies to all such clients, certain information included herein applies
to specific clients only.
The Firm currently serves as the investment adviser, on a discretionary basis, to the following
private pooled investment vehicles:
• Satori Fund I LP, a Delaware limited partnership (the “Domestic Fund”);
• Satori Fund Ltd., a Cayman Islands exempted company (the “Offshore Fund”);
• Satori Master Fund Ltd., a Cayman Islands exempted company (the “Master Fund”),
which serves as the master fund into which the Domestic Fund and Offshore Fund invest
substantially all of their assets through a “master feeder” structure; and
• Satori Fund II LP, a Delaware limited partnership (“Fund II”).
The Domestic Fund, the Offshore Fund, and the Master Fund are collectively referred to as “Fund
I” and together with Fund II, the “Funds”. Fund I General Partner serves as the general partner
of the Domestic Fund. Fund II General Partner serves as the general partner of Fund II. The
Offshore Fund and the Master Fund are governed by their respective Boards of Directors.
Fund I and Fund II generally operate side-by-side.
In providing advisory services to the Funds, the Firm pursues a long-short strategy focused
on
long-term capital appreciation by primarily investing in the securities (including debt, derivatives
and equity) of companies across a broad range of industries primarily in the United States but also
internationally. Please see “Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss”
for a description of the Funds’ investment strategies and certain related risks.
As used herein, the term “client” generally refers to the Funds and to any other private investment
fund or account that the Firm may advise in the future.
This Brochure does not constitute an offer to sell or solicitation of an offer to buy any securities.
The securities of the Funds are offered and sold on a private placement basis under exemptions
promulgated under the Securities Act of 1933, as amended and other applicable state, federal or
non-U.S. laws. Significant suitability requirements apply to prospective investors in the Funds,
including requirements that they be “accredited investors” as defined in Regulation D, “qualified
purchasers” as defined in the Investment Company Act, as amended, or non-“U.S. Persons” as
defined in Regulation S. Persons reviewing this Brochure should not construe this as, and should
understand that this Brochure is not, an offer to sell or a solicitation of an offer to buy the securities
of any of the Funds described herein. Any such offer or solicitation will be made only by means
of a confidential private placement memorandum.
C. Tailored Advisory Services for Client Accounts
The Firm manages assets in accordance with the stated investment objectives of each client as set
forth in the respective confidential offering memorandum and governing documents (collectively,
"Offering Documents"), or an investment management agreement or similar agreement (an
“IMA”).
Investment advice is provided directly to a Fund and not individually to the limited partners,
shareholders, and investors in a Fund (the “Investors” or “Fund Investors”).
The Firm may enter into “side letters” or similar agreements with certain Investors that may waive
or modify the application of or grant special or more favorable rights with respect to, the Offering
Documents to the extent permitted by applicable law.
D. Wrap Fee Programs
The Firm does not participate in wrap fee programs.
E. Assets Under Management
The Firm manages, on a discretionary basis, approximately $71,607,000 of client regulatory assets
under management. This figure for regulatory assets under management was determined as of
April 1, 2024. The Firm does not manage any assets on a non-discretionary basis.