For purposes of this Brochure, the “Adviser” means Columbia Capital, L.P., a Delaware limited
partnership formed in January 1999 (“Columbia Capital”), together with Boundary Street Capital, LP,
a Delaware limited partnership formed in July 2019 (“Boundary Street”). Columbia Capital and
Boundary Street are under common control and are not operationally independent, so they are together
registered with the SEC under an Umbrella Registration, with Boundary Street being considered a
“Relying Adviser” of Columbia Capital for purposes of Form ADV. The Adviser is principally led and
managed by Jason Booma, James Fleming, Patrick Hendy, Monish Kundra and John Siegel (the
“Managing Partners”).
The Adviser provides investment advisory, management and other services on a discretionary
basis exclusively to private investment funds (each a “Fund”, “Client”, or “Partnership,” and
collectively, the “Funds”, “Clients”, or “Partnerships”), for sophisticated, qualified investors
(“Investors” or “Limited Partners”).
The general partner or equivalent of each Fund is, or will be, an affiliate of the Adviser (each
a “General Partner”). Each General Partner is, or will be, subject to the Advisers Act pursuant to the
Adviser’s registration in accordance with SEC guidance. This Brochure also describes the business
practices of the General Partners, which operate as a single advisory business together with the Adviser.
The governing documents of each Client may also provide for the establishment of parallel or other
alternative investment vehicles in certain circumstances. Investors may participate in such vehicles for
the purposes of certain investments, and if formed, such vehicles would also become Clients of the
Adviser. In this Brochure, because it is uncertain whether such additional parallel or alternative
investment vehicles will be classified as Clients of the Adviser, when we refer to a Fund or Client, we
are also referring to such additional parallel or alternative investment vehicles, if any.
The Funds are generally structured as venture capital, private credit, or other types of private
funds that generally invest through negotiated transactions in operating entities, generally referred to
herein as “portfolio companies.” The Adviser’s investment advisory services to the Funds consist of
identifying and evaluating investment opportunities, negotiating the terms of investments, managing
and monitoring investments and achieving dispositions for such investments. Columbia Capital
generally pursues a sector-focused, stage-independent investment strategy in the Communications and
Technology (“C&T”) sector, typically through an equity interest in portfolio companies, targeting three
principal investment areas – Mobility, Enterprise Technology, and Digital Infrastructure. Boundary
Street’s investment strategy is to provide primarily debt to privately-held, growth-stage businesses in
Digital Infrastructure, Digital Services, and Enterprise Software areas of the C&T sector.
The Adviser’s advisory services to each Fund are detailed in the applicable Fund’s private
placement memoranda or other offering documents, investment management agreements, limited
partnership or other operating agreements (each,
a “Partnership Agreement”), subscription agreements
or similar governing documents, and are further described below under “Methods of Analysis,
Investment Strategies and Risk of Loss.” While it is anticipated that each of its Clients will pursue the
general strategy of either Columbia Capital or Boundary Street described above, as applicable, the
Adviser may tailor the specific advisory services with respect to each Client to the individual
investment strategy of that Client. In addition, the governing documents of Clients may, in certain
limited circumstances, impose restrictions on investing in certain securities or types of securities, for
example in connection with regulatory or compliance reasons.
Investors in the Funds participate in the overall investment program for the applicable Fund
but may be excused from a particular investment due to legal, regulatory or other agreed-upon
circumstances pursuant to the relevant governing documents. The Funds and the General Partners have
entered, and will in the future enter, into side letters or other similar agreements (“Side Letters”) with
certain Investors that have the effect of establishing rights under, or altering or supplementing the terms
(including economic or other terms) of, the relevant governing documents with respect to such
Investors. Except as otherwise agreed by the applicable General Partner, the specific rights and benefits
contained in any Side Letters are not required to be made available or disclosed to other Investors in
the applicable Fund or other Funds.
Additionally, from time to time and as permitted by the relevant governing documents, the
Adviser expects to provide (or to agree to provide) co-investment opportunities (including the
opportunity to participate in co-invest vehicles) to certain Investors or other persons, including other
sponsors, market participants, finders, consultants and other service providers, the Adviser’s personnel
and/or certain other persons associated with the Adviser and/or its affiliates (e.g., a vehicle formed by
the Adviser to co-invest alongside a particular Fund’s transactions). Such co-investments typically
involve investment and disposition of interests in the applicable portfolio company at the same time
and on the same terms as the Fund making the investment. However, from time to time, for strategic or
other reasons, a co-investor or co-invest vehicle may purchase a portion of an investment from one or
more Funds after such Funds have consummated their investment in the portfolio company (also known
as a post-closing sell-down or transfer). Any such purchase from a Fund by a co-investor or co-invest
vehicle generally occurs after the Fund’s completion of the investment and may be at different terms.
Where appropriate, and in the Adviser’s sole discretion, the Adviser is authorized to equitably adjust
the purchase price for market conditions, and to seek reimbursement to the relevant Fund for related
costs and expenses. However, to the extent such amounts are not so charged or reimbursed, they
generally will be borne by the relevant Fund.
As of December 31, 2023, the Adviser manages approximately $5,998,340,156 in Client assets
on a discretionary basis through the Funds.