A. Advisory Firm Description. The Adviser is a Delaware limited liability company and has its
principal place of business in Dallas, Texas. The Adviser was formed in 2015 by its founders,
Neil Shahrestani and Chart Westcott. Vikram Khanna joined the Adviser prior to the launch of
its business and is also considered a co-founder. Chart Westcott retired from his managerial
positions at the Adviser in 2022, but the principal owners continue to be (directly or indirectly)
Neil Shahrestani and Chart Westcott.
B. Advisory Services Offered. The Adviser provides discretionary investment advisory services
to clients structured as (i) private investment funds comprised of sophisticated, qualified
investors, including but not limited to, high net worth individuals, pension plans, funds of funds,
family offices, endowments and other institutions (each, a “Fund” and together, the “Funds”);
and (ii) separately managed accounts generally organized for the benefit of private investment
funds for which the Adviser acts as a sub-adviser, but that may also be beneficially owned
directly by high net worth individuals, retirement plans, trusts, partnerships, corporations or
other institutions (each, a “Separate Account” and together, the “Separate Accounts” and,
collectively with the Funds, the “Clients”). The Funds are generally organized in a master-
feeder structure in which the master fund is a Cayman Islands exempted limited partnership, and
the feeder funds include a U.S.-domiciled feeder fund organized as a Delaware limited
partnership and a non-U.S. domiciled feeder fund organized as a Cayman Islands exempted
company. The feeder funds invest all or substantially all of their assets in, and conduct their
investment activities indirectly through, the master fund. See Item 7 “Types of Clients” of this
Brochure for additional discussion on types of Clients and investors therein.
The Adviser seeks to generate consistently high, risk-adjusted returns for its Clients that are
uncorrelated to the broader market. The Adviser seeks to achieve this objective primarily
through employing a fundamental
approach to identify investment opportunities across the
biotechnology and pharmaceutical sub-sectors in an effort to construct a portfolio of high
conviction ideas with asymmetric risk/reward payoffs. See Item 8 “Methods of Analysis,
Investment Strategies and Risk of Loss” of this Brochure for additional information on the
Adviser’s investment strategy.
C. Tailored Advisory Services. While each of its Clients follows the general investment objective
and strategy stated above, the Adviser provides specific advisory services with respect to each
Client based on the particular investment objectives and strategies described in the applicable
Client’s (i) confidential offering memorandum or separate account agreement (as applicable)
and (ii) governing documents (referred to collectively as “Offering Documents”), and not in
accordance with the individual objectives of any particular underlying investor or beneficial
owner of a Client. The Offering Documents of the Funds generally contain no restrictions on
investing in any type of security. However, the Offering Documents of the Separate Accounts
generally do set forth certain specific investment guidelines and parameters that have included
restrictions on investing in (or limiting exposure to) certain types of securities, which can result
in disparate performance compared with other Clients employing a similar investment objective
and strategy.
D. Wrap Fee Arrangements. The Adviser does not participate in wrap fee agreements.
E. Amount of Client Assets. As of December 31, 2023, the Adviser’s regulatory assets under
management were $565,157,554.00 in discretionary assets and $0.00 in non-discretionary
assets.
All information is this Brochure with respect to the investment objective and strategy of any
Client of the Adviser (or any other term applicable to a specific Client) is qualified in its
entirety by reference to the Offering Documents of such Client. There can be no assurance
that any Client will achieve its investment objective or that an investment in any Client will be
profitable.