Boardman Bay Capital Management LLC (“Boardman,” “we” or “us”) filed our initial
application to register as an investment adviser with the SEC on March 31, 2014 under the
Investment Advisers Act of 1940, as amended (the “Advisers Act”).
Boardman Bay is a Delaware limited liability company that was formed in April 2012. We are
directly or indirectly owned by William B. Graves and trusts for the benefit of his family
members. Mr. Graves is the managing member of, and ultimately controls, Boardman.
Boardman Bay GP LLC is the general partner (the “Hedge Fund GP”) of Boardman Bay
Onshore, LP (the “Onshore Fund”) and the adviser of Boardman Bay Master, Ltd. (the “Master
Fund,” and together with the Onshore Fund, the “Hedge Funds”). Boardman Bay Ventures GP
LLC is the general partner (the “Ventures Fund GP”) of Boardman Bay Ventures, LP (the
“Ventures Fund”) and Boardman Bay Optical GP LLC is the general partner (the “Optical Fund
GP,” and together with the Hedge Fund GP and the Ventures Fund GP, the “General Partners”) of
Boardman Bay Optical Opportunities, LP (the “Optical Fund,” and together with the Hedge
Funds and the Ventures Fund, the “Funds”). Similar to Boardman, each General Partner is
directly or indirectly owned by William B. Graves, and trusts for the benefit of his family
members. Mr. Graves is the managing member of each General Partner. Each General Partner is
a “relying adviser” as that term is described in the SEC Staff No-Action Letter, dated January 18,
2012, to the American Bar Association, Business Law Section. Unless and only to the extent that
the context otherwise requires, references to Boardman herein are deemed to include references to
each General Partner.
We provide discretionary investment advice to the Funds. Notwithstanding the foregoing, we are
required to invest all of the capital of the Onshore Fund in shares of the Master Fund, other than
cash and cash equivalents held for investment into the Master Fund, distributions to investors
and/or payment of operating expenses. In the future, we may provide discretionary and/or non -
discretionary investment advice to other private investment funds and/or separately managed
accounts.
Other than in respect of the Ventures Fund and the Optical Fund, our general investment and
trading objective with respect to our clients is to maximize long-term returns and preserve capital
primarily by taking long and short positions in individual U.S. and non-U.S. equity securities,
through investments in public companies and other more liquid-type assets, as well
as private
companies or other restricted or illiquid assets. We seek to generate returns on both the long and
short sides of the portfolio. We generally seek to engage in a trading and investment strategy
with an emphasis on generating superior long-term returns versus the broader market. We
generally focus on the equities of companies in the global technology, media and telecom
(“TMT”) subsectors in various stages of their life cycle, although we may opportunistically invest
in other sectors as well. However, our trading mandate is broad and encompasses virtually ever y
type of asset, investment interest, security and property (real or personal) which can be trad ed or
purchased. In our discretion, we may also invest in Crypto-Assets.
The Ventures Fund is structured as a multi-series Delaware limited partnership (each, a “Series”).
In general, the strategy of each Series is to maximize capital appreciation by making an
investment in a single non-public company, and to hold such investment until the initial public
offering of the applicable company or some other disposition or monetization event in respect of
such company and investment. As each Series is legally distinct and separate from each other
BOARDMAN BAY CAPITAL MANAGEMENT LLC Form ADV: Part 2A Page 4
Series and pursues its own distinct investment strategy, unless the context otherwise requires,
general reference herein to a “Fund” shall refer to each Series of the Ventures Fund as well.
Our general investment and trading objective with respect to the Optical Fund is to maximize
long-term returns by taking long and short positions in individual U.S. and non-U.S. equity
securities related to the global optical communications equipment and components sector. We
seek to generate returns primarily through long exposure to single name securities that we believe
have high return-on-investment (ROI) prospects.
We generally do not permit investors in the private investment funds we manage to impose
limitations on the investment activities described in the offering documents for those funds.
Under certain circumstances, we may contract with a client to adhere to limited risk and/or
operating guidelines imposed by the client. We negotiate such arrangements on a case by case
basis. (See Item 16 “Investment Discretion.”)
We do not participate in wrap fee programs.
As of December 31, 2023, we managed approximately $62,197,986 in regulatory assets under
management on a discretionary basis. We do not manage any assets on a non-discretionary basis.