Breakwater Management LP, established in January 2007, is a California limited partnership specializing in discretionary investment management services for private investment vehicles. The firm, led by managing partner Eric Beckman, focuses on private equity investments in media & entertainment, marketing, and tech-enabled services sectors. Breakwater manages four private investment vehicles structured as limited partnerships, fully invested with approximately $169.2 million in regulatory assets as of December 31, 2022. The firm charges management fees ranging from 1.5% to 2.0% per annum based on the cost basis of invested capital for its Funds. Breakwater tailors its advisory services to each Client's needs, managing them in accordance with specific investment objectives and limitations. The firm also engages in performance-based fees and side-by-side management, subject to certain conditions. Breakwater's investment strategy primarily involves direct investments in lower middle market companies, focusing on senior secured loans and private equity. The firm emphasizes risk management and potential conflicts of interest, ensuring compliance with regulatory requirements. Clients are limited to accredited investors, qualified clients, and qualified purchasers, with minimum investment requirements and suitability criteria. Breakwater maintains a Code of Ethics to prioritize clients' interests and compliance with federal securities laws. The firm does not participate in soft dollar arrangements, receive client referrals from broker-dealers, or have directed brokerage dealings. Overall, Breakwater provides discretionary investment management services with a focus on private equity opportunities in specific sectors, emphasizing risk management and regulatory compliance.