Crystal Rock Capital Management, LLC., an Illinois limited liability company (the “Firm,” “Crystal Rock,” “we,” or “us”), is an investment adviser registered with the United States Securities and Exchange Commission (“SEC”). Crystal Rock was formed in 2005, and began managing Crystal Rock Fund, LLC (the “Fund”), in June 2006, with an objective of producing superior risk adjusted equity investment returns through a disciplined process of individual stock selection and constructing and managing a “high- conviction” concentrated portfolio. The Fund is a privately offered investment fund that was organized in December 2005 as a Delaware limited liability company and is open for investment by qualified investors. While Crystal Rock expects to focus primarily on the common stocks of U.S. companies for the investment portfolios of the Fund and its other client accounts, from time to time it may invest a portion of managed assets in the common stock of non-U.S. companies or in securities that are convertible into equity or otherwise may be a proxy for equity. Crystal Rock does not expect to use “leverage” (i.e., margin financing) in making investments, nor engage in stand-alone short selling, nor use options or other derivatives.
• The Firm has been an SEC Registered Investment Advisor since February 2012.
• The Firm is owned by Jay H. Freedman as the Managing Member. Crystal Rock Holdings, LLC, an Illinois limited liability company (“Holdings”) is a special member of the Fund which is also owned by Jay Freedman as Managing Member. Under the terms of the Fund, Holdings will receive the Incentive Allocation from the Fund, as described further in this Brochure.
• The Firm’s Chief Compliance officer is Jay H. Freedman, who is assisted by Andrew Starr
• The Firm is registered as an investment adviser because it serves as the investment manager of the Fund, and also serves as the investment manager of separately managed investment accounts for a select number of clients (the “Managed Accounts”).
• The Fund is excluded from the definition of the term “investment company” under Section 3(c)(1) of the Investment Company Act of 1940, as amended (the “1940 Act”); therefore, it is not required to register as an investment company under the 1940 Act. Crystal Rock’s Investment Management Services Overview Crystal Rock serves as the investment manager of the Fund and a select number of Managed Accounts. For all purposes in this Brochure, the Fund and each Managed Account client shall be deemed a “client” of Crystal Rock. Crystal Rock has sole and complete responsibility for managing its clients’ investment portfolios pursuant to the investment objectives and investment policies of such clients. (See Item 15 – Investment Discretion for more information). Crystal Rock’s investment decisions are made collaboratively by Crystal Rock’s investment professionals. Typically, Crystal Rock’s Chief Investment Officer, Jay H. Freedman, and at least one other analyst will analyze and review the relevant investment merits of each security. Each Crystal Rock principal is responsible for monitoring client holdings and potential investments within his individual areas of expertise. Investors in the Fund will receive a copy of the Fund’s Private Offering Memorandum and Operating Agreement and will be required to execute a subscription agreement in order to subscribe for limited liability company interests in the Fund. The foregoing Fund documents are referred to in this Brochure as the “Fund Offering Materials”. Investment Objectives and Strategies Crystal Rock’s investment objective for its clients is to focus on the publicly-traded equities of companies which are competitively advantaged, well-managed companies (typically expected to be 50-75% of the portfolio), or those with not-yet-fully recognized emerging growth opportunities. Crystal Rock also anticipates that a portion of the investment opportunities which are uncovered will come from either special situations (such as turnarounds, spin-offs, or supply/demand imbalances) or intra-sector pair trades, which involve buying an “undervalued” and selling an “overvalued” security within the same industry (such pair trades not expected to be more than 10% of the portfolio). It is expected that

the client’s portfolio will be relatively concentrated, consisting of approximately 20 core positions. Positions generally will be initiated at less than 10% of the portfolio as a percentage of overall portfolio net assets, with no single position expected to exceed 15% of the portfolio. Crystal Rock does not believe it is competitively advantaged as market timers. Accordingly, cash levels will be a function of Crystal Rock’s ability to find potentially productive investments and are not expected to exceed 15%. The foregoing percentages represent working guidelines only. Positions will not necessarily be reduced or liquidated in the event these percentages are exceeded in a given instance. While Crystal Rock expects its investment focus to be primarily on the publicly-traded common stock of U.S. companies, from time to time it also may invest a portion of client assets in the common stock of non-U.S. companies or in other securities that are convertible into equity or that otherwise may be a proxy for equity, such as preferred stock or convertible securities. From time to time, Crystal Rock also may direct its client accounts to invest in initial public offerings of equity securities (i.e., “new issues”). Crystal Rock does not expect to use “leverage” (i.e., margin financing) in making investments for its clients, nor does it expect to engage in stand-alone short selling or to use options or other derivatives. Fund and Managed Account Services Crystal Rock’s primary business is to manage the investments of the Fund. Qualified investors who are permitted to subscribe for limited liability company interests of the Fund will become investing members of the Fund. Crystal Rock also manages Managed Accounts for a select number of clients outside of the Fund, pursuant to the same (or substantially similar) investment strategy as the Fund’s investment strategy. Clients that open a Managed Account will be required to sign an investment management agreement with Crystal Rock setting forth the terms on which Crystal Rock will manage the client’s account and giving Crystal Rock discretionary power of attorney over the assets of the account (each, an “Investment Management Agreement”). Tailoring of Advisory Services to Individual Needs of Clients All management and investment decisions regarding client accounts are based on the objectives, strategies and policies of the particular client. Crystal Rock, as investment manager of the Fund, is responsible for all major decisions of the Fund, including, without limitation, amending or changing the Fund’s investment objectives, investment strategies and investment policies or limitations. Managed Accounts are typically managed with the same objectives and strategies as those applied to the Fund, however, the Firm will tailor a managed portfolio based on client preferences as agreed with the Firm. Investment Specialization Crystal Rock’s area of investment specialization is equities. The Firm performs fundamental analysis to determine individual stock selection and manages relatively concentrated equity portfolios. Stock selection is based on traditional, bottom-up, fundamental equity analysis with a goal of developing longer- term investment insights. As part of the investment process, the Firm employs a proprietary cash flow- based valuation framework. Types of Investments. Crystal Rock provides investment advice on the following types of investments.
• Exchange-listed stocks
• Stocks traded over-the-counter
• Foreign stocks Crystal Rock may also utilize No-Load Mutual Funds or Exchange Traded Mutual Funds on a limited basis. Crystal Rock does not provide advice on warrants, corporate debt securities (other than commercial paper), commercial paper, certificates of deposit, municipal securities, variable life insurance, variable annuities, United States government securities, options contracts on securities and commodities, futures contracts on tangibles and intangibles, interests in partnerships investing in real estate, oil and gas interests, hedge funds and other types of private (i.e., non-registered) securities. Assets Under Management As of December 30, 2022, the firm manages $135,032,701 and all assets are managed on a discretionary basis.