Ghost Tree Capital

Ghost Tree Capital, LLC, established in April 2013, is a registered investment adviser based in Puerto Rico. The firm specializes in providing discretionary investment advisory services to private funds and sub-advised funds, focusing on generating absolute returns primarily in the healthcare industry. The firm's investment strategy involves utilizing a long/short equity approach with a focus on biotechnology, pharmaceuticals, medical devices, and healthcare services. Ghost Tree manages approximately $359,964,950 of client regulatory assets on a discretionary basis as of December 31, 2023. Clients are required to be "qualified purchasers" with a minimum investment of $1 million to participate in the funds. The fee structure includes management fees, performance fees, and allocations, with expenses detailed in the advisory contracts. The firm may receive performance-based compensation, creating potential conflicts of interest, which are managed through documented procedures. Ghost Tree's investment analysis involves researching critical value drivers in the healthcare industry to identify compelling investments. The firm's Code of Ethics ensures compliance with federal securities laws, and the firm has discretion over client investments. Ghost Tree has custody over the funds' assets and has the authority to vote client securities. Ghost Tree does not currently manage any client assets on a non-discretionary basis. The firm does not have any disciplinary events that are material to client evaluation. Ghost Tree's financial information does not indicate any impairments in meeting contractual commitments to clients. For more information, visit www.adviserinfo.sec.gov or contact the Chief Compliance Officer at 917-836-0072 or [email protected].