Fees and Compensation — Form ADV Part 2A (3/20/2026)
[Brochure]
5: Fees and Compensation). We do not manage any funds or accounts that do not pay
performance-based compensation, but the differences in performance-based compensation
creates a potential conflict of interest. We manage this conflict through trade allocation
policies that generally allocate each trade pro rata among clients based on relative assets
under management, with certain exceptions as specified in the policy.
Account Minimums and Types of Clients — Form ADV Part 2A (3/20/2026)
[Brochure]
7. Types of Clients
Blue Grotto provides investment advisory services to certain separately managed accounts
and to BlueGrotto Master Fund LP, Blue Grotto Capital Partners LP and Blue Grotto
Capital Cayman Ltd. (collectively, the “Fund”).
The underlying investors in the Fund typically include:
• Individuals;
• Trusts and estates;
• Endowments and Foundations
• Corporations, partnerships or other business entities;
• Individual retirement accounts;
• 401(k) plans;
• Pensions; and
• Profit-sharing plans.
The underlying investors in our managed accounts typically include corporations,
partnerships, endowment foundations, or other business entities.
Investment Requirements
To invest in the Fund, we generally require a minimum investment of $1,000,000, although
at times we may waive this requirement.
To comply with Securities and Exchange Commission regulations, we require that U.S.
investors in the Fund qualify as both accredited investors and qualified purchasers.
Filed 2025-12-19 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $1,000,000 · Remaining Indefinite · Duration More than one year · Net Assets Decline to Disclose
AUM Breakdown
Accounts
AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals)
0
0.0
(b) Individuals (high net worth individuals)
0
0.0
(c) Banking or thrift institutions
0
0.0
(d) Investment companies
0
0.0
(e) Business development companies
0
0.0
(f) Pooled investment vehicles
3
0.7
(g) Pension and profit sharing plans
0
0.0
(h) Charitable organizations
4
1.4
(i) State or municipal government entities
0
0.0
(j) Other investment advisers
0
0.0
(k) Insurance companies
0
0.0
(l) Sovereign wealth funds and foreign official institutions
0
0.0
(m) Corporations or other businesses not listed above