Spruce House Investment Management LLC

Spruce House Investment Management LLC, established in September 2006, is an investment advisory firm based in New York. The firm, managed by Zachary Sternberg and Benjamin Stein, specializes in providing discretionary investment advisory services to private pooled investment vehicles known as Partnerships. The firm exercises broad and flexible investment authority tailored to each Partnership's specific investment objective and strategy. As of December 31, 2024, the firm managed approximately $3.55 billion in client regulatory assets under management on a discretionary basis. For fees, the firm charges a 1.0% annual Management Fee based on the value of each investor's account, payable quarterly in arrears. Additionally, a 20% Incentive Allocation based on realized and unrealized profits is charged to each Partnership. The firm may also receive Ancillary Fees for services provided to portfolio companies, which are used to offset Management Fees owed by investors. Investment strategies focus on achieving long-term capital appreciation through the purchase and long-term ownership of common stock. The firm may invest in various securities, including micro to medium capitalization companies, and engage in short sales, special situations, and non-U.S. securities. Risk factors include currency risks, margin borrowing, and business disruptions. The firm operates as a fiduciary, acting in the best interests of its clients. Clients have limited control over investment decisions, as the firm provides services on a discretionary basis. The firm has no disciplinary events to disclose and complies with proxy voting policies to vote in the best interests of clients.