9AT: HARSPRING CAPITAL MANAGEMENT, LLC

other names

HARSPRING CAPITAL MANAGEMENT, LLC

Adviser Profile

As of Date	03/30/2026
ADV Location	NEW YORK, NY, United States
Adviser Type - Large advisory firm
Number of Employees	4
of those in investment advisory functions	3
Registration	SEC, Approved, 07/15/2020
Other registrations (1)	SEC, ERA - Withdrawn, 06/15/2020
Former registrations	HARSPRING CAPITAL MANAGEMENT, LLC

AUM^*	459,104,363 -34%
of that, discretionary	459,104,363 -34%
Private Fund GAV^*	361,617,722 -27%
Avg Account Size	114,776,091 -50%
SMA’s	No
Private Funds	4 2
Contact Info	646 xxxxxxx

Client Types

- Pooled investment vehicles

Advisory Activities

- Portfolio management for pooled investment vehicles

Compensation Arrangments

- A percentage of assets under your management
- Performance-based fees

Fund Type	Count	GAV
Fund TypeHedge Fund	Count3	GAV$361,617,722
Fund TypeOther Private Fund	Count1	GAV$

Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser GUARDIAN POINT CAPITAL, LP	Hedge Fund646.4m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV646.4m	AUM646.4m	#Funds1
Adviser ALMITAS CAPITAL LLC	Hedge Fund1.1b	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV1.1b	AUM1.1b	#Funds2
Adviser BERYL CAPITAL MANAGEMENT, LLC	Hedge Fund855.3m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV855.3m	AUM1.0b	#Funds4
Adviser RAYS CAPITAL PARTNERS LIMITED	Hedge Fund514.6m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV514.6m	AUM547.2m	#Funds7
Adviser WYNKOOP LLC	Hedge Fund208.9m	Liquidity Fund-	Private Equity Fund10.4m	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV219.3m	AUM1.2b	#Funds6
Adviser BAYBERRY CAPITAL PARTNERS LP	Hedge Fund533.4m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV533.4m	AUM533.4m	#Funds3
Adviser INTEGRAL HEALTH ASSET MANAGEMENT, LLC	Hedge Fund60.2m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV60.2m	AUM1.9b	#Funds3
Adviser PINNBROOK CAPITAL MANAGEMENT LP	Hedge Fund1.1b	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV1.1b	AUM1.1b	#Funds4
Adviser POWER SUSTAINABLE INVESTMENT MANAGEMENT INC.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM515.2m	#Funds-
Adviser EVR RESEARCH LP	Hedge Fund365.0m	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV365.0m	AUM365.0m	#Funds3

Stock Ticker	Stock Name	$ Position	% Position	$ Change	# Change
Stck Ticker29357K103	Stock NameEnova International, Inc.	$ Position$35,448,600	% Position13.00%	$ Change37.00%	# Change0.00%
Stck Ticker237266101	Stock NameDarling Ingredients Inc.	$ Position$32,940,000	% Position12.00%	$ Change17.00%	# Change0.00%
Stck Ticker30303M102	Stock NameMeta Platforms, Inc.	$ Position$29,374,005	% Position11.00%	$ Change-10.00%	# Change0.00%
Stck Ticker023135106	Stock NameAmazon.com, Inc.	$ Position$28,667,844	% Position11.00%	$ Change5.00%	# Change0.00%
Stck Ticker19239V302	Stock NameCogent Communications Holdings, Inc.	$ Position$30,237,900	% Position11.00%	$ Change-10.00%	# Change60.00%
Stck Ticker02079K107	Stock NameAlphabet Inc.	$ Position$21,228,570	% Position8.00%	$ Change29.00%	# Change0.00%
Stck Ticker90041L105	Stock NameTurning Point Brands, Inc.	$ Position$19,674,600	% Position7.00%	$ Change10.00%	# Change0.00%
Stck Ticker65249B109	Stock NameNews Corporation	$ Position$15,711,180	% Position6.00%	$ Change-18.00%	# Change-3.00%
Stck Ticker52603A208	Stock NameLendingClub Corporation	$ Position$16,288,400	% Position6.00%	$ Change25.00%	# Change0.00%
Stck Ticker44891N208	Stock NameIAC Inc.	$ Position$12,316,500	% Position5.00%	$ Change-26.00%	# Change-36.00%

Brochure Summary

Overview

Harspring Capital Management, LLC (hereinafter “Harspring”, “we”, “us”, “our” or the “Firm”) is a Delaware, limited liability company founded in February 2012. The Firm’s principal place of business is in New York, New York and Harry M. Gail is the principal owner. We are an affiliate of Harspring Capital Advisors, LLC (the “Fund General Partner”). Harspring provides discretionary investment management services to private pooled investment vehicles including Harspring Capital, LP, a Delaware, Limited Partnership (the “Master Fund”) and Harspring Capital Offshore Ltd., a Cayman Exempt Limited Company (the “Offshore Fund”). The Master Fund, the Offshore Fund, and other private funds to which we provide investment management services are each referred to as a “Fund” or “Client”, and collectively referred to as the “Funds” or the “Clients”. Our investment decisions and advice with respect to each Fund are subject to each Fund’s investment objectives and guidelines, as set forth in its respective offering documents (“Offering Documents”) and/or our investment management agreement. Limited partners or shareholders of the Funds for which a Harspring affiliate serves as the general partner, who we refer to as “Investors,” do not have the ability to impose restrictions on the Funds’ investments. Where we provide investment management services to other private

funds for which we are not the general partner, the services we provide are subject to the terms of our investment management agreement with such client, which would reflect the investment objectives and guidelines of the client. We do not currently participate in any Wrap Fee Programs. As of December 31, 2023, we have regulatory assets under management $690,801,000 managed on a discretionary basis and no assets under management on a non-discretionary basis. This Brochure does not constitute an offer to sell or a solicitation of an offer to buy any securities. The Funds’ securities are offered and sold on a private placement basis under exemptions promulgated under the “Securities Act” of 1933 and other applicable state, federal or non-U.S. laws. Significant suitability requirements apply to prospective Investors in the Funds, including requirements that they be “Accredited Investors” as defined in Securities Act and “qualified purchasers” as defined in the Investment Company Act of 1940. Persons reviewing this Brochure should not construe this as an offer to sell or a solicitation of an offer to buy the securities of any of the Funds described herein. Any such offer or solicitation will be made only by means of a confidential private placement memorandum.

HARSPRING CAPITAL MANAGEMENT, LLC

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