Strategy Capital LLC

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Strategy Capital LLC
CRD #169007
SEC #801-114124
CIK #0001592413
AUM 1,344.5 M (2026-03-02)
Employees 7 (57% Investors, 0% Brokers)
Fees
Minimum
Phone650-917-8700
Address1 First Street
Los Altos, CA 94022-2756
Source [IAPD] [EDGAR] [Website] [LinkedIn]
Total AUM ($M)
1400112084056028002002201020182027
Fees and Compensation — Form ADV Part 2A (3/2/2026) [Brochure]
Item 5 – Fees and Compensation

A. Management Fee

   Fees payable by the Partnerships to Strategy Capital are negotiable and may vary by separate agreement
   with particular Investors without the approval or notice to other Investors.

   From the 2013 Partnership, Strategy Capital typically receives a management fee, as a percentage of each
   Investor’s capital account, on the first business day of each quarter, payable in advance. The management
   fee for the 2013 Partnership is generally 0.25% per quarter (approximately 1.00% per annum).

   Strategy Capital will pro-rate the management fee for the 2013 Partnership for Investors that hold for less
   than a full quarter or a full month, however, Investors will not receive a refund of the management fee if
   they withdraw capital prior to the end of a quarter.

   From the 2019 Partnership, Strategy Capital typically receives a management fee as a percentage of each
   Investor’s capital account calculated separately for each Investor at 0.0833% (approximately 1.0% per
   annum) as of the beginning of each month payable in advance and prorated as to Capital Contributions
   made on a date other than the first day of a month.

   From the 2023 Partnership, Strategy Capital does not receive a management fee.

   From the Sub Advised Account, Strategy Capital is compensated by an asset-based management fee,
   payable monthly in arrears and calculated as a percentage or rate on all assets comprising the portfolio,
   which rate decreases as Strategy Capital’s assets under management, excluding Sub Advised Account
   assets and assets of Strategy Capital and its affiliates (‘‘Total Manager Assets’’), increases. For purposes
   of this calculation, ‘‘Sub Advised Account assets’’ means the daily average over the applicable period of
   Sub Advised Account assets plus the assets of other funds advised by the Sub Advised Account sponsor
   or its affiliates that are managed by Strategy Capital. The asset-based fee rate ranges from 0.75% per year
   when Total Manager Assets is less than or equal to $100 million to a blended rate between 0.1875% and
   0.10% per year when Total Manager Assets exceed $2 billion, with five total breakpoints.

   Please consult the Client’s Constituent Documents for complete information regarding calculation and
   payment of Strategy Capital compensation arrangements.

B. Expenses
   Generally, each Partnership is responsible for its own operating expenses, including any fees, costs or
   expense of the Partnership, Strategy Capital or its affiliates reasonably incur in connection with the
   operation of the business and maintenance of such Partnership. Expenses include but are not limited to:

      •   expenditures made by or on behalf of the Partnerships (including amounts a Partnership’s General
          Partner and its Affiliates advance) in connection with the Partnerships formation and organization;
      •   commissions and other transaction related compensation and charges arising out of transactions
          involving Partnership assets, including costs and expenses associated with using a service
          provider unaffiliated with a Partnership’s General Partner to provide an outsourced trading
          function;
      •   interest on margin and other borrowings, interest and other borrowing charges on Investments
          sold short, and custodial and bank service fees;
      •   costs directly related to research regarding Investments and potential Investments (including
          travel in connection with such research and costs of third party analytical services);
      •   auditing, accounting, administration, bookkeeping, appraising, tax preparation, legal, and other
          professional fees and costs, including fees and costs paid to a Partnership’s General Partner’s
          counsel for services relating to the Partnership’s legal affairs (which include fees and costs

       involved in documenting or negotiating special arrangements Investor or prospective Investor),
       fees and costs in connection with lawsuits, arbitrations, and other controversies, fees of third party
       administrators, and other costs and liabilities, as defined in the agreement) and costs incurred by
       the Partnership’s Partnership Representative, in its capacity as such;
   •   costs incurred in connection with the offer and sale of Interests, including printing, copying, travel,
       and travel-related costs associated with the preparation of the Partnership’s offering materials and
       the offer and sale of Interests;
   •   costs arising out of licensing, governmental registration, and membership in self-regulatory
       organizations of or by the Partnership and its affiliates (other than a Partnership’s General
       Partner), and costs associated with regulatory and other filing and reporting requirements by or
       related to the Partnership, including filings required of a Partnership’s General Partner and its
       Affiliates as a result of their involvement in the management of or provision of services to the
       Partnership (including Form PF);
   •   transfer, withholding, income, stamp, and other taxes and duties imposed on the Partnership or
       Partners (subject to a Partner’s liability therefor pursuant to Section 7.7);
   •   costs of Partnership reporting, and costs related to Partner meetings and other Partnership
       governance activities (including obtaining Partner Consents);
   •   the Partnership’s allocable share of the costs related to the operation and/or administration of any
       collective investment vehicle (including a “master fund” or similar entity) in which the
       Partnership holds an ownership interest;
   •   other Partnership costs related to the management and operation of the Partnership and/or the
       purchase, sale, or transmittal of Investments and other Partnership assets, all as a Partnership’s
...
Account Minimums and Types of Clients — Form ADV Part 2A (3/2/2026) [Brochure]
Item 7 – Types of Clients

Strategy Capital provides investment advice and management to Partnerships and Sub-Advised Accounts
as described above.

Prospective Investors in the Partnerships must meet eligibility criteria and are subject to certain
withdrawal requirements and limitations as set forth in the Partnerships’ Constituent Documents.
Prospective Investors are encouraged to thoroughly review the respective Partnership’s Constituent
Documents and any other materials provided by Strategy Capital, which set forth all of the terms in detail.
Strategy Capital may waive, reduce, increase, or alter requirements in particular cases and may change
them as to new Investors in the future.

Depending on the Partnership, Interests are offered to “accredited investors” (as defined in Regulation D
under the Securities Act of 1933) and to “qualified purchasers” (as defined in the Investment Company
Act of 1940, as amended (the “1940 Act”)). The minimum initial investment in the 2013 Partnership is
$500,000; the minimum initial investment in the 2019 Partnership is $25,000,000; the minimum
investment in the 2023 Partnership is $50,000.
Sector Form 13F Holdings Value ($M)
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Facebook Inc 85.6
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Astera Labs Inc 38.6
View All
Holdings by Sector ($M)
1600128096064032002017202020232027
Type Form D Funds Date Sold AUM
VC Strategy Capital Growth Investors I LLC [2025-02-25] 25.2 M 10.2 M
Filed 2025-07-09 (D/A) · Exemption 506(b), 3(c), 3(c)(7) · Minimum $50,000 · Remaining Indefinite · Duration More than one year · Revenue Decline to Disclose
HF Strategy Capital International Investors LP 2025-02-25 38.5 M
HF Strategy Capital Institutional Investors LP [2020-03-30] 621.8 M 791.1 M
Filed 2025-05-27 (D/A) · Exemption 506(b), 3(c), 3(c)(1), 3(c)(7) · Minimum $50,000 · Remaining Indefinite · Duration More than one year · Commission $23,750 · Net Assets Decline to Disclose
Other Strategy Capital SPV I LLC [2018-09-12] 5.0 M 20.6 M
Offered $5,050,000 · Filed 2018-04-25 (D) · Exemption 506(b), 3(c), 3(c)(7) · Duration One year or less · Net Assets Decline to Disclose
HF Strategy Capital Investors LP [2013-10-29] 191.1 M 574.7 M
Filed 2025-05-27 (D/A) · Exemption 506(b), 3(c), 3(c)(1), 3(c)(7) · Minimum $10,000 · Remaining Indefinite · Duration More than one year · Commission $23,750 · Net Assets Decline to Disclose
AUM Breakdown Accounts AUM ($M)
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 1 71.3
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 4 1,273.2
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(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 0 0.0
(n) Other 0 0.0
Total 5 1,344.5
By Discretionary
Discretionary 5 1,344.5
Non-Discretionary 0 0.0
Total 5 1,344.5
By Non-United States Persons
Non-United States Persons 38.5
United States Persons 1,306.0
Total 5 1,344.5
Form D Directors Role # Filings # Firms 2011 - 2026
John Rutherford Executive Officer 15 3
Hamilton Dr Helmer Executive Officer 4 1
Strategy Capital LLC Executive Officer, Promoter 4 1
Strategy Capital GP LLC Executive Officer 2 1
EDGAR Form CIK 2011 - 2026
13F-HR [0001592413]
D [0001592413]
Firm Profile (Form ADV)
ServesInstitutional
Fund TypesHedge Fund
LEI254900GTCZBJ0EJ1X972
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