A. Describe your advisory firm, including how long you have been in business. Identify
your principal owner(s).
Advisory Business
GREE Capital Partners, LLC (“GCP”), was formed in November of 2018 as a Delaware limited
liability company. GREE LP Fund US (“GLF” and together with GCP, the “Firm”) is a relying
adviser of GCP. GLF was formed in July of 2022, as a Delaware limited liability company.
The Firm provides investment advice and management to private pooled investment funds and special
purpose vehicles not registered under the Investment Company Act of 1940, as amended (the
“Investment Company Act”) (collectively referred to as the “Funds” or “Clients”).
The Firm tailors its advisory services to the specific investment objectives and restrictions of its Funds,
consistent with each Fund’s governing document. Generally, the Firm employs a venture capital and
emerging growth equity strategy with an investment objective to seek income and gain through the
acquisition, holding, distribution or other disposition of securities of pre-seed and seed stage start-up
companies with a primary focus in the North American gaming, media and entertainment industries.
The Funds managed by GCP will typically employ a venture strategy by making direct investments in
start-up companies. The Funds managed by GLF employ a fund of funds strategy by investing in
other private funds with underlying venture-related investments. For each of the Funds, an affiliate
of the Firm serves as its general partner with authority to make investment decisions on its behalf.
Principal Owners/Ownership Structure
GCP is wholly owned by GREE Capital US Holding, LLC which is wholly owned by GREE, Inc. a
publicly traded company headquartered in Tokyo, Japan. GLF is wholly owned by GREE LP Fund
US Holdings, LLC which is wholly owned by GREE, Inc. Mr. Tanaka Yoshikazu is the principal
owner of GREE Inc.
B. Describe the types of advisory services you offer. If you hold yourself out as
specializing in a particular type of advisory service, such as financial planning, quantitative
analysis, or market timing, explain the nature of that service in greater detail. If you provide
investment advice only with respect to limited types of investments, explain the type
of investment advice you offer, and disclose that your advice is limited to those types of
investments.
The Funds advised by GCP are private pooled investment funds or special purpose vehicles that
employ a venture capital and emerging growth equity strategy. The Funds advised by GLF are private
pooled investment funds that employ a fund of funds strategy by investing
in other private funds that employ
a venture capital and emerging growth equity strategy.
C. Explain whether (and, if so, how) you tailor your advisory services to the individual
needs of clients. Explain whether clients may impose restrictions on investing in certain
securities or types of securities.
The Firm does not tailor its advisory services to the individual needs of investors in its Funds; the
Firm’s investment advice is tailored to the investment objectives of each Fund. The objectives of
each Fund are described in the limited partnership agreement, or other governing document, of a
Fund (collectively the “Governing Documents”). Investors determine the suitability of an
investment in a Fund, based on, among other things, these Governing Documents which outline
applicable investment risks.
Fund investors generally cannot impose restrictions on investing in certain securities or types of
securities. Investors participate in the overall investment program for the applicable Fund but can be
excused from a particular investment due to legal, regulatory or other applicable constraints, pursuant
to the terms of the applicable Governing Documents. In accordance with industry common practice,
a Fund’s general partner may enter into side letters or similar agreements with certain investors in the
Funds that have the effect of establishing rights under, or altering or supplementing the terms of, the
relevant agreement with respect to such investors. Examples of side letter rights that could be entered
into include certain fee provisions, information rights, liquidity and withdrawal provisions,
concentration limits, notification provisions and most favored nations provisions. These rights,
benefits or privileges are not always made available to all investors nor are they required to be disclosed
to all investors, consistent with general market practice.
D. If you participate in wrap fee programs by providing portfolio management services,
(1) describe the differences, if any, between how you manage wrap fee accounts and how you
manage other accounts, and (2) explain that you receive a portion of the wrap fee for your
services.
The Firm does not participate in wrap-fee programs.
E. If you manage client assets, disclose the amount of client assets you manage on
a discretionary basis and the amount of client assets you manage on a non-discretionary basis.
Disclose the date “as of” which you calculated the amounts.
The Firm manages $165,764,827 in regulatory assets under management on a fully discretionary basis.
The Firm does not manage Client assets on a non-discretionary basis.