Blue Grotto Capital, LLC

Blue Grotto Capital, LLC, established in June 2018 by Benjamin Gordon, offers investment advisory services to pooled investment vehicles, single-investor investment vehicles, and separately managed accounts. The firm focuses on achieving high absolute returns through individual equity securities for long and short positions, emphasizing unrecognized market opportunities for alpha generation. Blue Grotto tailors services to clients' needs and investment mandates, with a 3-year investment horizon. As of December 31, 2024, the firm had discretion over $1,163,937,572 in regulatory assets under management. Clients are charged an asset-based fee of 1.0%-1.5% annually and a performance-based profit allocation of 10%-20% of net profits, subject to specific limitations. The firm does not participate in wrap fee programs and requires a minimum investment of $1,000,000 for certain funds. Blue Grotto employs Bayesian updating for position sizing, behavioral psychology in decision-making, and actively manages investment behaviors. The firm's investment strategies focus on key issues for probabilistic outcomes and risk mitigation, with considerations for market, operational, and cybersecurity risks. Blue Grotto has a Code of Ethics to ensure compliance and transparency in client transactions and personal trading activities. The firm has custody of client assets through qualified custodians and accepts discretionary authority to manage client securities accounts, adhering to the investment strategy outlined in private placement memoranda or governing documents. Voting client securities is done in the best interests of clients, with a policy to generally align with company management but vote against when necessary. Blue Grotto does not solicit prepayment exceeding $500 or have financial conditions impairing contractual commitments.