Nine Ten Capital Management LLC, (“Nine Ten”) formed in March 2014, is a limited liability
company located in Chicago, Illinois. Nine Ten received its registration from the Securities and
Exchange Commission in May 2014. The Adviser provides discretionary investment management
services to Nine Ten Partners LP (the “Fund”) through Limited Partner interests. The Fund is exempt
from registration under the Investment Company Act of 1940, as amended (“Investment Company
Act”). This is currently Nine Ten’s only strategy offered.
Four individuals have an equity stake in Nine Ten. Two owners of Nine Ten are also principals,
owners, and/or employees of Bares Capital Management, Inc., (“Bares Capital”) a registered
investment advisor with the SEC since 2005. Bares Capital is considered an affiliated investment
adviser only due to the ownership mentioned above.
The Fund
On July 1, 2014, the Adviser launched the Fund with assets converted from Bares Capital’s Micro-
Cap Strategy separate accounts. The Micro-Cap Strategy is no longer offered at Bares Capital and
legacy separate account owners invested in this strategy have either joined the Fund in a tax neutral
transaction or have liquidated their accounts.
The Adviser’s services to the Fund are provided pursuant to an investment management agreement
(the “Investment Management Agreement”) with the General Partner of the Fund, which is an
affiliate of Nine Ten. In accordance with the terms of the Investment Management Agreement, the
General Partner has delegated to the Adviser all of its authority under the Fund's Limited Partnership
Agreement (the "Partnership Agreement") to manage and operate the Fund and formulate
investment policy with full discretion. The Investment Management Agreement requires the Adviser
to manage the investments of the Fund, subject to and in accordance with the Fund's investment
objectives and limitations provided in the Partnership Agreement and Private Placement
Memorandum (“PPM”).
The Fund seeks to maximize growth of capital through a portfolio of primarily long positions in
publicly-traded equity securities focused on smaller companies, while retaining the flexibility
necessary to invest opportunistically across all market capitalizations. The Fund will also have the
ability to utilize short sales and options, make opportunistic credit investments and invest in
restricted and private
securities. The Adviser will focus its research on small companies, including
micro-cap companies, which we believe is the most inefficiently priced, publicly-traded asset class.
While not part of the Fund’s core investment approach, the Fund may also selectively invest in
options, other derivative instruments and restricted and private securities, as well as participate in
direct equity financings in public companies, short sale opportunities, investments outside of the
United States and investments in parts of a company’s capital structure other than common stock.
Advisory Services
The Adviser tailors its advisory services to the specific investment objectives and restrictions of the
Fund pursuant to the investment guidelines and restrictions set forth in the Fund’s PPM, Partnership
Agreement and other governing documents (collectively, the “Governing Documents”). Information
about the Fund and the particular investment objectives, strategies, restrictions, and risks associated
with an investment in the Fund are described in detail in the Governing Documents, which are made
available to investors only through the Adviser and its authorized agents.
Fund investors do not receive customized investment management services. With the exception of
the investment restrictions articulated in the Fund’s Investment Management Agreement, investors
in the Fund are not permitted to impose restrictions on the Adviser’s investment discretion.
Investments in the Fund involve significant risks and should be regarded as long-term in nature, and
therefore should represent only one portion of an investor’s diversified investment portfolio. Please
see Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss for more information about
the risks associated with an investment.
Non-managed assets are not accommodated by the Adviser.
Nine Ten has approximately $471,782,287 in discretionary assets under management as of
December 31, 2023.
The Adviser does not provide legal, tax or accounting advice or services and a client should not
assume that Nine Ten is providing such services at any time. Also, securities or other investments
on which the Adviser provides advice are not deposits or obligations or any bank, are not endorsed
or guaranteed by any bank and are not insured by the Federal Deposit Insurance Corp., the Federal
Reserve Board, or any government agency and that Nine Ten is not a trust or banking institution.