Case File
efta-efta01386223DOJ Data Set 10CorrespondenceEFTA Document EFTA01386223
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DOJ Data Set 10
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efta-efta01386223
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AGP LP 519 Alpha Group Capital Paul Barren
Item 3.
Disciplinary Information
Not applicable.
Item 4.
Other Business Activities
Alkeon is the sole Member of SilverBay Capital Management, LLC, a Delaware limited liability
company ("SilverBay") that was formed in August 2009, which is also registered as an
investment adviser with the SEC. Alkeon's personnel (through SilverBay) manage ACAP
Strategic Fund and Bluepoint Investment Series Trust, both registered investment companies,
and may manage other registered investment funds in the future.
Some of Alkeon's personnel also are registered representatives and employees of Breakwater
Group, LLC ("Breakwater"), a broker-dealer that may be deemed to be affiliated with Alkeon.
Currently, Breakwater assists in the distribution of the ACAP Strategic Fund and Bluepoint
Investment Series Trust and does not have a trading function
Additional information about
SilverBay is available on the SEC's Investment Adviser Public Disclosure website, and
additional information about Breakwater is available on FINRA's website.
Item 5.
Additional Compensation
Not Applicable.
Item 6.
Supervision
Alkeon has implemented a Code of Ethics, which governs the supervised persons' activities,
including the investment advice that each provides to clients. Greg Jakubowsky (Alkeon's Chief
Compliance Officer) and Jennifer Shufro (Alkeon's Managing Director of Legal and
Compliance) supervise Alkeon's supervised persons by monitoring their compliance with
Alkeon's Code of Ethics. Their telephone numbers are
respectively.
Item 7.
Requirements for State-Registered Advisers
Not Applicable.
4
0708&001177112411.1,1
CONFIDENTIAL - PURSUANT TO FED. R. CRIM. P. 6(e)
DB-SDNY-0087819
CONFIDENTIAL
SDNY GM_00234003
EFTA01386223
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