Spruce Point Capital Management, LLC

Spruce Point Capital Management, LLC is an SEC-registered investment adviser founded in 2009 and based in Riverhead, New York. The firm specializes in providing investment portfolio management on a discretionary basis to private pooled investment vehicles, including Spruce Point Research Activism Partners LP, Spruce Point Research Activism Partners Offshore, Ltd, and Spruce Point Research Activism Master Fund LP. The firm's Chief Investment Officer is Benjamin Axler, and the Chief Compliance Officer and Chief Operating Officer is Daniel Oliver. Spruce Point requires a minimum initial investment of $1,000,000 for Limited Partners in the Funds, with additional contributions of at least $100,000 permitted at the General Partner's discretion. The firm charges management fees ranging from 0.95% to 2.5% per annum, calculated based on the net asset value of each capital account. Performance fees, ranging from 20% to 30% of net capital appreciation, are subject to a high-water mark provision. The firm's investment philosophy focuses on sharing investment research publicly to achieve appreciation in investments with reduced correlation to traditional asset classes. Spruce Point conducts in-depth reviews of companies' financial history, management track records, and product/services competitiveness to determine target valuations and investment decisions. Spruce Point has not been involved in any legal or disciplinary events related to clients. Benjamin Axler, the Chief Investment Officer, holds a B.S. and B.A. in Statistics and Business and a Masters in Statistics. He has extensive experience in investment banking and capital markets. For more information, you can contact Daniel Oliver, the Chief Compliance Officer, at (914) 999-2019 or [email protected].