a) Background Heights LLC (hereinafter “HEI” or “the Adviser”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in May 2021, and the principal owner is Heights Corp. Alexandre David Cohen is the majority owner of Heights Corp. HEI provides discretionary and non-discretionary investment management services to managed accounts and to private funds’ portfolios which are exempt from registration as investment companies under the Investment Company Act of 1940, as amended, the interests of which are exempt from registration under the Securities Act of 1933, as amended, pursuant to certain private placement exemptions for qualified and institutional investors on a fully discretionary basis. b) Advisory Services Separately Managed Accounts HEI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. HEI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring HEI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. HEI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of HEI’s economic, investment or other financial interests. To meet its fiduciary obligations, HEI attempts to avoid, among other things, investment, or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, HEI’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is HEI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Funds Heights Fund I LP The primary purpose of the Partnership is to make investments primarily focused on growth companies, with selective early- stage investments, in companies with a heavy “brand” component, high user/customer engagement, and differentiated product/service offerings (“Investment Focus”). SPVs Mindful Heights LLC The purpose of the Company is to provide a limited number of select investors with the opportunity to realize long-term appreciation, through venture capital investments in equity and equity-related securities of OrangeDot, Inc. (the “Portfolio Company”). The general purpose of the Company is to exercise all rights, powers, privileges, and other incidents of ownership or possession with respect to Securities held or owned by the Company; to enter into, make, and perform all contracts and other undertakings; and to engage in all activities and transactions as may be necessary, advisable, or desirable to carry out the foregoing. Dill Project LLC The purpose of the Company

is to hold one or more prospective investments in Major League Pickleball Inc. or any of its affiliated entities and to engage in such other businesses or activities as the Manager deems necessary, advisable, convenient, or incidental thereto. Services Limited to Specific Types of Investments HEI limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. HEI may use other securities as well to help diversify a portfolio when applicable. c) Tailored Advice and Client-Imposed Restrictions HEI will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by HEI on behalf of the client. HEI may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent HEI from properly servicing the client account, or if the restrictions would require HEI to deviate from its standard suite of services, HEI reserves the right to end the relationship. d) Sub-Advisory Relationship HEI may also provide Investment Management Services as a sub-adviser; in other words, a client may engage an independent investment adviser (the "Sponsor") which, in turn, will engage HEI to provide portfolio management services to all or part of its clients' portfolios. In this situation, HEI will receive a portion of the fee charged by the independent adviser to the client. HEI may provide advisory services on investing in private investment partnerships, including partnerships for which HEI’s related persons serve as general partner, managing member or manager. Because some types of investments involve certain additional degrees of risk, they will only be implemented / recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. Certain clients have an interest in IPO’s. While this is not part of the Adviser’s strategy, HEI will provide advisory services to clients who choose to participate. Clients must consider whether a separate account relationship is appropriate to their own circumstances based on all relevant factors including, but not limited to, the Client’s or investor’s own investment objectives, liquidity requirements, tax situation and risk tolerance. Prospective clients and investors are strongly encouraged to undertake appropriate due diligence, including but not limited to a review of relevant relating to the proposed investment program for the Separate Account and the additional details about HEI’s investment strategies, methods of analysis and related risks in Item 8 of this Brochure, before making a decision to hire the Adviser. e) Wrap Fee Disclosure A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. HEI does not participate in any wrap fee programs. f) Assets Under Management As of December 31, 2023, HEI had $ $192,732,567 in assets under management.