9AT: GRAVITY CAPITAL MANAGEMENT LLC

Adviser Profile

As of Date	03/30/2026
Registration	SEC, Approved, 04/27/2020
Other registrations (3)	New York, Terminated, 04/20/2020 Indiana, Terminated, 06/26/2015 Texas, Failure to Renew, 12/31/2011
ADV Location	NEW YORK, NY, United States
Contact Info	917 xxxxxxx

AUM^*	94,034,321 39%
of that, discretionary	94,034,321 44%
Number of Employees	2
of those in investment advisory functions	2
Private Fund GAV^*	0 -100%
Avg Account Size	2,612,064 85%
% High Net Worth	40.00% 23%
SMA’s	Yes
Private Funds	0 1

Adviser Type

- Mid-sized advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Pension and profit sharing plans
- Charitable organizations
- Insurance companies
- Other

Advisory Activities

- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management
- Fixed fees (other than subscription fees)
- Performance-based fees

Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser CARMIKA PARTNERS LLP	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM72.6m	#Funds-
Adviser GRUENSTEIN INVESTMENTS LLC	Hedge Fund20.5m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV20.5m	AUM61.5m	#Funds1
Adviser DILATION CAPITAL MANAGEMENT LP	Hedge Fund456.7m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV456.7m	AUM228.8m	#Funds3
Adviser KDHB V CAPITAL MANAGEMENT, LLC	Hedge Fund54.8m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV54.8m	AUM54.8m	#Funds1
Adviser DARK HORSE CAPITAL MANAGEMENT LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM77.0m	#Funds-
Adviser POLPO CAPITAL MANAGEMENT LLC	Hedge Fund209.5m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV209.5m	AUM299.5m	#Funds2
Adviser NEWLANDS INVESTMENT MANAGEMENT PTE LTD.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM41.3m	#Funds-
Adviser WALNUT LEVEL CAPITAL LLC	Hedge Fund31.2m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV31.2m	AUM119.2m	#Funds3
Adviser UPRIGHT FINANCIAL CORP	Hedge Fund16.9m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV16.9m	AUM98.0m	#Funds1
Adviser ORRELL CAPITAL MANAGEMENT	Hedge Fund4.5m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV4.5m	AUM238.9m	#Funds1

Brochure Summary

Overview

ADVISORY BUSINESS A. Description of Advisory Firm Gravity Capital Management, LLC (also referred to as the “Firm”, “GCM” or the “Adviser”) was founded in 2003 by Adam Seessel. Mr. Seessel is the current principal and sole owner of GCM. GCM is organized as a limited liability company in the State of Delaware. GCM conducts investment advisory activities in separately managed accounts (“SMAs”). GCM expects to invest in mainly long positions in publicly traded equity securities in U.S. and non-U.S. issuers. In certain circumstances, investments in short positions and options on financial indices and individual securities may be used to hedge investments in the SMAs. GCM also operates the Gravity Long‐Biased Fund, LP (“the Fund”) as a concentrated, value-oriented portfolio. The Fund seeks long-term capital appreciation by investing its assets primarily in equity securities. From time to time in executing this strategy, the Firm may use leverage. GCM expects that the Fund will invest primarily in common stocks, but is permitted, pursuant to the Fund’s investment management agreement and offering and governing documents, to use cash and/or short positions in equities and equity exchange-traded funds (“ETFs”). The Fund will invest primarily in the securities of U.S. companies, but GCM will also invest in companies outside of the U.S., as necessary, in meeting

the Fund’s investment mandate. B. Description of Advisory Services GCM provides day-to-day portfolio management services and has discretion to purchase and sell securities for the Fund and the SMAs (each of the Fund and the SMAs, a “Client” and collectively, the “Clients”). The Fund and the SMAs expect to be invested in primarily publicly traded equity securities of public issuers. In certain circumstances, investments in options on financial indices and individual securities may be used to establish or increase long or short positions or to hedge the Clients’ investments. While GCM expects to invest primarily in domestic equity securities, GCM is not limited in the type of investments used to achieve the Clients’ investment mandates. C. Availability of Customized Services for Individual Clients The Clients are generally managed in accordance with GCM’s investment mandate with its Clients and are not tailored to any particular investor. While it is discouraged, SMAs may formally request to impose certain restrictions relating to their investment. D. Wrap Fee Programs GCM does not participate in a wrap fee program. E. Assets Under Management As of December 31, 2023, GCM manages a total of $67,891,887 in regulatory assets under management. GCM manages $65,248,551 on a discretionary basis and $2,643,336 on a non- discretionary basis. ~ 5 ~

GRAVITY CAPITAL MANAGEMENT LLC

GRAVITY CAPITAL MANAGEMENT LLC

GRAVITY PARTNERS

Adviser Profile

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Brochure Summary

Overview

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GRAVITY CAPITAL MANAGEMENT LLC GRAVITY CAPITAL MANAGEMENT LLC GRAVITY PARTNERS

Adviser Profile

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Brochure Summary

Overview

GRAVITY CAPITAL MANAGEMENT LLC

GRAVITY CAPITAL MANAGEMENT LLC

GRAVITY PARTNERS