9AT: WESTERLY CAPITAL MANAGEMENT LLC

other names

WESTERLY CAPITAL MANAGEMENT LLC

Adviser Profile

As of Date	03/28/2025
Adviser Type - Large advisory firm
Number of Employees	3
of those in investment advisory functions	2
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Other registrations (2)	SEC, ERA - Withdrawn, 06/30/2022 California, ERA - Withdrawn, 06/30/2022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

AUM^*	288,038,866 40.78%
of that, discretionary	288,038,866 40.78%
Private Fund GAV^*	288,038,866 18.79%
Avg Account Size	144,019,433 40.78%
SMA’s	No
Private Funds	2
Contact Info	415 xxxxxxx
Websites

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

Fund Type	Count	GAV
Fund TypeHedge Fund	Count2	GAV$288,038,866

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 BARCA CAPITAL, LLC	Hedge Fund301.3m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV301.3m	AUM324.5m	#Funds2
Adviser SPRINGHOUSE CAPITAL MANAGEMENT, LP	Hedge Fund167.6m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV167.6m	AUM167.6m	#Funds1
Adviser BRIZO CAPITAL, LP	Hedge Fund136.1m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV136.1m	AUM240.6m	#Funds1
Adviser BLACK MAPLE CAPITAL MANAGEMENT LP	Hedge Fund144.9m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV144.9m	AUM298.3m	#Funds4
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-
Adviser 3B CAPITAL MANAGEMENT, LP	Hedge Fund236.1m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV236.1m	AUM236.1m	#Funds4
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 SMP ASSET MANAGEMENT, LLC	Hedge Fund216.6m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV216.6m	AUM280.4m	#Funds1
Adviser TERRA PARTNERS ASSET MANAGEMENT	Hedge Fund218.4m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV218.4m	AUM218.4m	#Funds3
Adviser EVERGREEN CAPITAL ASSOCIATES LLC	Hedge Fund222.7m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV222.7m	AUM229.0m	#Funds8

Stock Ticker	Stock Name	$ Position	% Position	$ Change	# Change
Stck Ticker46090E953	Stock NamePUT QQQ 510 07/18/25 (PUT)	$ Position$25,500,000	% Position9.00%	$ Change13.00%	# Change0.00%
Stck Ticker925550105	Stock NameVIAVI SOLUTIONS INC	$ Position$21,902,250	% Position8.00%	$ Change1.00%	# Change13.00%
Stck Ticker74346Y103	Stock NamePROS HOLDINGS INC	$ Position$15,644,340	% Position6.00%	$ Change183.00%	# Change244.00%
Stck Ticker444144109	Stock NameHUDSON TECHNOLOGIES INC	$ Position$16,240,000	% Position6.00%	$ Change115.00%	# Change63.00%
Stck Ticker550241103	Stock NameLUMEN TECHNOLOGIES INC	$ Position$11,169,000	% Position4.00%	$ Change-13.00%	# Change-22.00%
Stck Ticker576853105	Stock NameMATRIX SERVICE CO	$ Position$11,078,200	% Position4.00%	$ Change-12.00%	# Change-19.00%
Stck Ticker00827B106	Stock NameAFFIRM HOLDINGS INC	$ Position$10,716,700	% Position4.00%	$ Change374.00%	# Change210.00%
Stck TickerG037AX101	Stock NameAMBARELLA INC	$ Position$9,447,295	% Position4.00%	$ Change	# Change
Stck Ticker00486H105	Stock NameADTRAN HOLDINGS INC	$ Position$8,745,750	% Position3.00%	$ Change20.00%	# Change17.00%
Stck TickerM25133105	Stock NameCOGNYTE SOFTWARE LTD -W/I	$ Position$7,854,000	% Position3.00%	$ Change-5.00%	# Change-20.00%

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.

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WESTERLY CAPITAL MANAGEMENT LLC

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