Gullane Capital, LLC is a limited liability company formed under the laws of the State of Delaware and
headquartered in Memphis, Tennessee.
Richard A. Miller, III is the Managing Member of Gullane Capital. Richard A. Miller, III owns
85.75% of Gullane Capital.
Jennifer M. Miller is a member and owns 4.75% of Gullane Capital.
The Miller Family Trust dated December 23, 2020, owns 4.75% of Gullane Capital.
The Trip Miller Family Trust Dated June 4, 2021, owns 4.75% of Gullane Capital.
Gullane Capital filed its initial application to become registered as an investment adviser in May
2021, which was accepted on July 1, 2021.
Introduction
The investment advisory services of Gullane Capital are provided to you through an appropriately
licensed individual who is an investment adviser representative of Gullane Capital (referred to as your
investment adviser representative throughout this brochure).
Description of Advisory Services
The following are descriptions of the primary advisory services of Gullane Capital. Please understand
that a written agreement, which details the exact terms of the service, must be signed by you and Gullane
Capital before we can provide you with the services described below.
Private Fund Management Services
Gullane Capital provides investment advisory, management and other services to a privately offered
pooled investment vehicle (also known as and referred to as a “hedge fund” or “Fund”) which is intended
for investment by certain financially experienced and sophisticated investors who are (i) “accredited
investors” under Rule 501(a) of Regulation D of the Securities Act of 1933, as amended (the “Securities
Act”), and (ii) “qualified clients” under Rule 205-3 of the Investment Advisers Act of 1940, as amended
(the “Advisers Act”). Gullane Capital provides investment advisory, management and other services to
several Special-Purpose Vehicles which are private funds structured as hedge funds.
The pooled investment vehicle is Gullane Capital Partners, LLC, a Delaware limited partnership. Gullane
Capital is the Member Manager of the Company (the “Member Manager”) and in such a capacity is
responsible for managing and making all investment decisions on behalf of the Fund. The Member
Manager's duties and obligations with respect to the investment activities of Gullane Capital Partners,
LLC are performed primarily by Richard A. “Trip” Miller III.
The investment objective of the Fund is to make concentrated, long-term equity, fixed income, private
business, or options investments using a strict value investing philosophy. The Member Manager may
also utilize qualifying short investments. In order to minimize the risk of permanent capital loss the
Member Manager uses the following methodology: (i) to invest in companies whose core economics and
future prospects are fully understood by the Member Manager, (ii) to invest in companies whose
Gullane Capital, LLC Page 6 Form ADV Part 2A Firm Brochure
management is believed by the Member Manager to be capable and trustworthy, (iii) to invest in
companies that have permanent competitive strategic advantages that allow them to earn a high return
on equity for an extended period of time and (iv) to invest in
companies the Member Manager believes
are trading at a significant discount of conservative appraised value or less.
Limits Advice to Certain Types of Investments
Gullane Capital provides investment advice on the following types of investments:
Securities Properly Exempted from Registration
Hedge Funds
Although we generally provide advice only on the products previously listed, we reserve the right to offer
advice on any investment product that may be suitable for each client’s specific circumstances, needs,
goals and objectives.
It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings
modestly as deemed appropriate based on risk tolerance and our expectations of market behavior. We
may modify our investment strategy to accommodate special situations such as low basis stock, stock
options, legacy holdings, closely held businesses or special tax situations.
(Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more
information.)
Tailored Advisory Services
We serve as the Member Manager to an affiliated Private Fund and Special-Purpose Vehicles (SPVs).
All management and investment decisions regarding our Private Fund and SPVs are based on the
individual fund objectives, strategies and policies. We are responsible for all major investment decisions
including, without limitation, amending or changing an individual Private Fund’s investment objective;
determining investment strategies; and establishing and implementing investment policies or limitations.
Client Assets Managed by Gullane Capital
As of December 31, 2023, Gullane Capital has $260,716,002 in discretionary assets under management
and $0 in non-discretionary assets under management to report. Discretionary assets total derived from
the third-party prepared capital statements by our Fund Administrators at Strategic Fund Services.
At the time of this annual amendment, not all fund’s Dec 31, 2023, capital valuations were available to
Gullane Capital or Strategic Fund Services. The following funds had Dec 31, 2023, capital valuations
totaling $ 69,534,402 - Gullane Mining Partners, LLC, Gullane Mining Partners II, LLC, Gullane Mining
Partners III, LLC, Gullane Digital Asset Partners, LLC and GULLANE DIGITAL ASSET PARTNERS QP,
LLC. The remaining funds capital valuations reflect values as of September 30, 2023 totaling $
191,181,600 - Gullane Technology Partners II, LLC, Gullane Technology Partners IV, LLC, Gullane
Technology Partners VI, LLC, Gullane Technology Partners VI-B, LLC, Gullane Technology Partners VII,
LLC, Gullane Technology Partners VII-QP, LLC, Gullane Technology Partners VII B, LLC , Gullane
Technology Partners VII B QP, LLC , Gullane Technology Partners VIII, LLC, Gullane Technology
Partners VIII-QP, LLC, Gullane Technology Partners IX, LLC, Gullane Technology Partners X, LLC,
Gullane Technology Partners X-QP, LLC, Gullane Technology Partners, LLC, Dune Technology Partners
I, LLC, Dune Technology Partners I-A, LLC, Dune Technology Partners II, LLC and Dune Technology
Partners III, LLC.
Gullane Capital, LLC Page 7 Form ADV Part 2A Firm Brochure
An ADV amendment will be made once all 12/31/23 fund valuations are obtained.