Advisory Business
A. General Description of Advisory Firm
11 Capital, a Delaware limited partnership formed in March 2019, is an investment adviser to
private fund clients and separately managed accounts. 11 Capital has been registered with the SEC
as an investment adviser since January 2020. Jason McDougall (the “Chief Investment Officer”)
is the principal owner of 11 Capital and has ultimate responsibility for its management and
investment decisions. 11 Capital Partners GP LLC, a Delaware limited liability company, serves
as the general partner of 11 Capital and is owned by Mr. McDougall and Brian Fieber, the Chief
Operating Officer and Chief Compliance Officer (the “Chief Compliance Officer”) and/or entities
owned or controlled by them or for the benefit of them and their families. 11 Capital has its
principal place of business in New York, New York.
11 Capital Fund GP LLC (the “Fund General Partner”), a Delaware limited liability company, is
an affiliate of 11 Capital and serves as the general partner of clients that are organized as U.S.
partnerships. 11 Capital and the Fund General Partner share facilities and personnel. The Fund
General Partner is owned by Mr. McDougall and Mr. Fieber and/or entities owned or controlled
by them or for the benefit of them and their families.
B. Description of Advisory Services
This Brochure generally includes information about 11 Capital and its relationships with their
clients. While much of this Brochure applies to all such clients, certain information included herein
applies to specific clients only.
11 Capital provides investment advisory services on a discretionary basis to the following private
fund clients (each a “Fund” and collectively, the “Funds”):
• 11 Capital Onshore Fund LP, a Delaware limited partnership (the “Domestic Fund”);
• 11 Capital Offshore Fund Ltd, an exempted company incorporated under the laws of the
Cayman Islands (the “Offshore Fund”); and
• 11 Capital Master Fund LP, a Cayman Islands exempted limited partnership (the “Master
Fund”), which serves as the master fund into which the Domestic Fund and the Offshore
Fund invest substantially all of their assets through a “master feeder” structure.
The Fund General Partner serves as the general partner of the Domestic Fund and the Master Fund.
The Offshore Fund is governed by its Board of Directors.
11 Capital also provides advisory services to separately managed accounts (the “Managed
Accounts”). The Managed Accounts pursue a substantially similar strategy to the Funds.
References throughout this document to “Clients” refer to the Funds and the Managed Accounts
listed above and to any other private investment funds
and separately managed accounts 11 Capital
may advise in the future.
In providing advisory services, 11 Capital pursues a global long/short equity strategy focused on
identifying investments that fit into proprietary frameworks and conducting detailed company-
specific research through the use of its internal investment process. Please see “Item 8: Methods
of Analysis, Investment Strategies, and Risk of Loss” for a description of 11 Capital’s investment
strategies and certain related risks. Notwithstanding the foregoing, subject to any limitations in the
governing documents of the Clients, 11 Capital is not limited with respect to the types of
investment strategies it may employ or the markets or instruments in which it may invest.
The securities of the Funds are offered and sold on a private placement basis under exemptions
promulgated under the Securities Act of 1933, as amended, and other exemptions of similar import
under U.S. state laws and the laws of other jurisdictions where any offering may be made.
Investors in the Funds must meet the qualifications set forth in the applicable offering documents.
Persons reviewing this Brochure should not construe this as an offer to sell or solicitation of an
offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will
be made only by means of a confidential private placement memorandum.
C. Tailored Advisory Services for Client Accounts
11 Capital manages assets in accordance with the stated investment objectives of each Client, as
described in any relevant investment management agreement or similar agreement (an “IMA”) or
in an offering memorandum or a Client’s organizational documents (together with the IMA and
the offering memorandum, the “Offering Documents”). Investment advice is provided directly to
Clients and not individually to the limited partners, shareholders, and investors in Clients (the
“Investors”). In the case of the Managed Accounts, 11 Capital manages those assets in accordance
with the stated investment objectives of such Managed Accounts’ IMA. 11 Capital intends for the
Funds and Managed Accounts to hold similar investments, to the extent practical, subject to
investment guidelines, tax, regulatory, and other considerations which may cause investments to
differ.
D. Wrap Fee Programs
11 Capital does not currently participate in wrap fee programs.
E. Assets Under Management
11 Capital manages, on a discretionary basis, approximately $399,343,000 of Client regulatory
assets under management. This figure for regulatory assets under management was determined as
of December 31, 2023. 11 Capital does not manage any assets on a non-discretionary basis.