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Infinitum Asset Management, LLC: investment adviser

Infinitum Asset Management, LLC is an investment adviser registered with the SEC (file 801-133803, CRD 333552). What it reports on Form ADV: assets and clients, fees, owners, disciplinary history and its client brochure. From the SEC's Investment Adviser Public Disclosure site; read Oct 21, 2026.

Assets managed
$1.1B
Discretionary
100%
Accounts
5
Employees
5
In advisory roles
3
Disclosures
0

Company page · SEC adviser record · Full Form ADV (PDF)

The firm reports no custody of client cash or securities.

Form ADV Part 1A, Item 5, as filed on the SEC Investment Adviser Public Disclosure site; read Oct 21, 2026.

Clients and fees

Whom the firm advises and how it is paid, from Items 5.D, 5.E and 5.G.

Client typeClientsAssetsShare
Private funds and other pooled vehicles5$1.1B100.0%

How it is paid

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

Services

  • Portfolio management for pooled investment vehicles (other than investment companies)

Who owns it

Schedule A lists direct owners of 5% or more (and officers who own a stake); Schedule B lists the owners of those owners.

Direct owners (Schedule A)

OwnerTypeRoleStakeSinceControlPublic company
Yetimoglu Enterprises IncCompany (U.S.)OwnerE 75% or moreJan 2019Yes
Cornack LtdCompany (outside the U.S.)ShareholderB 10% to 25%Jan 2024

Indirect owners (Schedule B)

OwnerOwns a stake inTypeStakeControlPublic company
Stanislas PoniatowskiCornack LtdPersonF General partner, trustee or managing memberYes
John Y YetimogluYetimoglu Enterprises IncPersonE 75% or moreYes

Form ADV reports ownership in bands, not exact stakes: A means 5% to 10%, B 10% to 25%, C 25% to 50%, D 50% to 75%, E 75% or more. F marks a general partner, trustee or managing member, a role that controls the firm without a percentage. Owners of less than 5% are not listed.

Form ADV Schedules A and B, via the SEC Investment Adviser Public Disclosure site.

Disciplinary history

The firm answered No to every disciplinary question on Form ADV (Item 11).

The brochure

Form ADV Part 2A: the plain-language document an adviser must give its clients. Each item is shown as filed; open an item to read all of it.

Infinitum Asset Management, LLC - Part 2A Brochure, filed Mar 31, 2026. Brochure PDF. Items: 4 · 5 · 6 · 7 · 8 · 9 · 10 · 11 · 12 · 13 · 14 · 15 · 16 · 17 · 18

Item 4. Advisory business

Infinitum Asset Management, LLC (hereinafter “Infinitum”, “we”, “us”, “our” or the “Firm”) is organized as a Florida limited liability company with a principal place of business Fort Lauderdale, Florida. Infinitum will provide discretionary investment management services to qualified investors through its private funds: Infinitum Cayman Master, Ltd.; Infinitum Cayman Ltd.; and Infinitum Partners, LP. We serve as the investment adviser, with discretionary trading authority, to private, pooled investment vehicles, the securities of which are offered through a private placement memorandum to accredited investors, as defined under the Securities Act of 1933, as amended, and qualified purchasers, as defined under the Investment Company Act of 1940, as amended.

Read the rest of Item 4 (516 more words)

We do not tailor our advisory services to the individual needs of any particular investor. Currently, Infinitum manages the following private, pooled investment vehicles:

Infinitum Cayman Ltd., a Cayman Islands exempted company (the “Offshore Fund”); Infinitum Partners, LP, a Delaware limited partnership (the “Onshore Fund”); Infinitum Cayman Master Ltd., a Cayman Islands exempted limited partnership (the “Master Fund”); Infinitum Ventures LLC, a Delaware Limited Liability Company; and Open Minds Ventures Limited, a British Virgin Island Limited Liability Company.

The Funds listed above are herein each referred to as a “Fund” or “Client” and collectively referred to as the “Funds” or the “Clients”. The Funds’ “Limited Partners” and “Shareholders” (as Applicable) are hereafter collectively referred to as the “Investors” where appropriate. Our investment decisions and advice with respect to the Funds are subject to each Fund’s investment objectives and guidelines, as set forth in its respective “Offering Documents.” The Funds primarily make public equity investments. The investment objective of the Partnership is to generate consistent uncorrelated alpha by identifying and exploiting mispricing created by company-specific events and market dislocations. The Investment Manager seeks to deliver asymmetric returns by focusing on smaller companies and lesstrafficked ideas. On the long side, the Investment Manager is disciplined, patient, and focused on any opportunity to take advantage of unwarranted market panic and forced selling in high quality companies represented by cycles driven by under-supply/growth of new products, exceptional management teams, strong cash flow/balance sheet, sustainable competitive advantage, and attractive valuation. On the short side, the Investment Manager seeks companies with 50% or more downside with a clear line of sight/catalyst(s) to impairment evidenced by unsustainable business models, fads, frauds, management issues, and/or cyclicals with oversupply. The Funds invest through negotiated transactions in operating entities. Investors in the Funds participate in the overall investment program for the applicable Fund but may be excluded from a particular investment due to legal, regulatory or other agreed-upon circumstances pursuant to the relevant partnership agreement. Each Fund or its General Partner (as defined below), from time to time, enter into side letters or other

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similar arrangements with certain investors that have the effect of establishing rights under, or altering or supplementing, the Fund’s partnership agreement.

Each Fund has a general partner that has the authority to manage the business and affairs of the Fund. The general partner(s) of the Funds are as follows: Infinitum Partners GP, LLC referred to herein individually as a “General Partner,” and collectively as the “General Partners”). The Adviser’s advisory services to each Fund are detailed in the applicable private placement memoranda and partnership agreements for such Fund and are further described below under “Methods of Analysis, Investment Strategies and Risk of Loss.” Each General Partner is subject to the Advisers Act pursuant to the Adviser’s registration in accordance with SEC guidance. This Brochure also describes the business practices of each General Partner, which operates as a single advisory business together with the Adviser. We do not currently participate in any Wrap Fee Programs. As of December 31, 2025, Infinitum managed approximately $1,138,676,308 regulatory assets under management on a discretionary basis.

Item 5. Fees and compensation

The fees applicable to each of the Funds are set forth in detail in the corresponding Offering Documents. A brief summary of such fees is provided below. Management Fee Infinitum is paid an investment management fee (“Management Fee”) per annum of the net asset value of the Funds. The Management Fee is received monthly at the rate of 2% on an annualized basis. The Investment Manager, in its sole discretion, may waive or modify the Management Fee for any Investor. Other Types of Fees or Expenses Infinitum is authorized to incur and pay in the name and on behalf of the Funds all expenses which they deem necessary or advisable.

Read the rest of Item 5 (865 more words)

The Firm is responsible for and shall pay, or cause to be paid, all of their own ordinary administrative and overhead expenses, including, without limitation, all costs and expenses related to rent, furniture, fixtures, equipment, office supplies, clerical expenses and all salaries, bonuses and benefits paid to, or on behalf of, personnel of the Firm. The Funds shall bear all operating expenses and other costs of the Funds including, but not limited to: (i) accounting, bookkeeping, tax and auditing fees and expenses (including the allocable share of the costs, fees and expenses relating to internal accounting and tax preparation functions); (ii) legal fees and expenses, including, but not limited to, fees and expenses incurred in connection with this Memorandum and the Funds Agreement, any

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offering of Partnership Interests, Partnership contracts and investments; (iii) all fees and disbursements of the Funds’, the General Partner’s and the Investment Manager’s attorneys, consultants and other third parties performing work benefiting the Funds or otherwise in connection with the Funds’ investment activities (including, without limitation, the legal and other fees, costs and expenses of such parties in or related to any proxy contest or other shareholder initiative or proceeding and in any threatened or actual litigation or governmental investigation or proceeding, and the amount of any judgments or settlements paid in connection with such proxy contest, shareholder initiative or litigation, or fines or penalties levied as a result of any such investigation or proceeding ); (iv) insurance and bonding costs; (v) all trading expenses and transaction costs, including, but not limited to, brokerage commissions and expenses relating to short sales, clearing and settlement charges, interest on loans and debit balances, margin interest, broker service fees and other clearing and custodial expenses; (vi) fees or assessments in connection with any regulatory registrations, qualifications and/or approvals of the Funds, the General Partner or the Investment Manager, and related compliance fees and expenses, deemed appropriate by the General Partner; (vii) such research and portfolio management expenses as the General Partner or the Investment Manager deems appropriate, which may include, but are not limited to, expenses incurred in connection with due diligence investigations or research as to investments or potential investments, including travel, lodging and other expenses incurred in connection with visits to companies, meetings, research symposiums and communications with company management, security holders, analysts and other third parties, costs of research reports, data feeds and databases, news wires and quotation services, periodical subscription fees and costs of software (including risk control) utilized by the General Partner or the Investment Manager in connection with managing the Funds’ portfolio; (viii) fees of the Funds’ registered agent; (ix) fees of the Administrator; (x) the cost of preparation and distribution of reports and statements to Limited Partners; (xi) all filing and recording fees; (xii) all custodial fees, bank service fees, and fees or expenses associated with insuring the Funds’ assets; (xiii) the Management Fee; (xiv) all applicable federal, state, local and foreign taxes payable by the Funds; and (xv) any extraordinary expenses, such as indemnification and litigation expenses. Notwithstanding the foregoing, any expense relating specifically to a Side Pocket Account shall be charged against the capital accounts of the Partners participating in such Side Pocket Account in proportion to their respective interests in such Side Pocket Account. Certain of the Funds’, the General Partner’s and/or the Investment Manager’s expenses may be borne or reimbursed by broker-dealers executing transactions for the Funds. Expenses incurred in the organization of the Funds will be borne or reimbursed by the Funds. For financial reporting purposes, organizational expenses will be amortized by the Funds during its first 60 months of operations. Amortization of such expenses over a period that is up to 60 months is a divergence from U.S. generally accepted accounting principles, which may, in certain circumstances, result in a qualification of the Funds’ annual audited financial statements. In such instances, the General Partner may make modifications to its accounting practices in order to eliminate such qualifications. In general, each Investor will bear its proportionate share of the Fund expenses on a pro rata basis with respect to the size of such Investor’s capital account(s) or with respect to the relative net asset value of the shares held by such Investor, as applicable. In addition, if the Partnership becomes, in the future, a shareholder or other interest holder in a master fund, the Partnership will indirectly bear its ratable portion of the costs and expenses of such master

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fund including, but not limited to, any and all of the types of expenses described above with respect to the Partnership. To the extent that expenses to be borne by the Funds are paid by the Firm or its affiliates, the Funds will reimburse the Firm or its affiliates for such expenses. We may waive any such reimbursement with respect to any Fund expenses. Any waiver by us for reimbursement of any Fund expenses shall not serve as a waiver of reimbursement for any future Fund expenses to be paid by us or our affiliates. Neither the Firm nor its employees accept compensation, including sales charges or service fees, from any person for the sale of securities or other investment products.

Item 6. Performance-based fees and side-by-side management

We and our affiliates are entitled to a performance-based compensation from all clients. As a result, we and our affiliates do not face certain conflicts of interest that may arise when an investment adviser accepts performance-based fees from some clients, but not from other clients. Performance-based allocation arrangements may create an incentive for us to recommend investments which may be riskier or more speculative than those which we would recommend under a different arrangement.

Item 7. Types of clients

Our clients are the Funds, as described in Item 4 above, and the Funds accept subscriptions only from individuals and institutional investors which qualify as “accredited investors.” The term “accredited investor” includes an individual who makes a written representation that he is the sole party in interest and either (A) has a net worth in excess of $1,000,000 (excluding the value of his or her primary residence) or (B) has had an individual income in excess of $200,000 in each of the two most recent years or joint income with his spouse in excess of $300,000 in each of those years and has a reasonable expectation of reaching the same

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income level in the current year; or (ii) an organization that has at least $5,000,000 in total assets or all beneficial interests in which are owned by individuals or other organizations. The minimum subscription is $1,000,000, except that the minimum subscription amount may be waived by the General Partner in its discretion.

Item 8. Methods of analysis, investment strategies and risk of loss

The descriptions set forth in this Brochure of specific advisory services that we offer to Clients, and investment strategies pursued and investments made by us on behalf of our Clients, should not be understood to limit in any way our investment activities. We may offer any advisory services, engage in any investment strategy and make any investment, including any not described in this Brochure, that we consider appropriate, subject to each Client’s investment objectives and guidelines as set forth in the Offering Documents. The investment strategies we pursue are speculative and entail substantial risks. Clients should be prepared to bear a substantial loss of capital. There can be no assurance that the investment objectives of any Client will be achieved.

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Investment Objective The investment objective of the Funds is to generate consistent uncorrelated alpha by identifying and exploiting mispricing created by company-specific events and market dislocations. The Investment Manager believes that short-term volatility is a by-product of equity investing and investor panic/overreaction creates substantial opportunities in the global equity markets on the long and short side. The investments will consist primarily of global equities, but the Partnership will be able to invest in other securities, including both debt and preferred stock. The goal of the Investment Manager is to buy securities that are trading at levels below their intrinsic values and sell short securities that are trading with market values above their intrinsic values by focusing on significant events that create this mispricing, business model, supply/growth cycles, business moat and management team of the company. By focusing on a few key elements/drivers of the business, the Investment Manager believes that superior risk-adjusted returns can be achieved uncorrelated with that of the overall market. Risk Management The Investment Manager believes that the best way to achieve long-term capital appreciation is by managing risk on a holistic basis. The Investment Manager will focus on capital preservation to limit mistakes/bias in order to protect against permanent impairment of capital. The Investment Manager seeks to line up asymmetric risk/reward and margin of safety on a position basis. The Investment Manager mitigates risk by focusing on high-quality companies on the long side and building in a significant margin of safety when we buy. Entry price discipline is a critical component of risk control. Short-selling is an overall strategy to reduce downside risk in addition to relative value/pair trading and tail-end hedges. The Investment manager will regularly rank portfolio holdings and focus on data points that provide clarity on probability of success/where we may be wrong. The Investment Manager will methodically build, size, and liquidate positions to manage bias and will cut net exposure actively if there is observation of a bear market through any combination of: inverted yield curve, weakness in debt spreads/high yield, weak market breadth, systemic risk to the banking system, PMI deterioration and significant inflation spikes. Risk of Loss Factors The following risk factors do not purport to be a complete list or explanation of the risks involved in an investment in the clients advised by us. These risk factors include only those risks we believe to be material, significant or unusual and relate to particular significant investment strategies or methods of analysis employed by us. An investment involves significant risks, and is suitable only for those persons who can bear the economic risk of the loss of their entire investment, who have limited need for liquidity in their investment, and who have met the conditions set forth in the Offering Documents. There can be no assurances that we will achieve our investment objectives. An investment carries with it the inherent risks associated with investments in publicly traded stocks and bonds, options, and related instruments, including, without limitation, the risks described below. Each prospective investor should carefully review the Offering Documents and the documents referred to herein before deciding to invest with Infinitum Asset Management, LLC.

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General Investment Risk. The Partnership’s investments will consist of securities identified by the Investment Manager’s methodology. Since such strategy involves identifying securities which are generally undervalued (or, in the case of short positions, overvalued) by the marketplace, success of such strategy necessarily depends upon the market eventually recognizing such value in the price of the security, which may not necessarily occur. The Partnership’s portfolio positions may undergo significant short-term declines and experience considerable price volatility. Since the General Partner’s methodology does not require any minimum market capitalization, the Partnership may take positions in smaller capitalization companies or other issuers which may involve an increased level of general investment risk. Equity positions may include speculative securities. Accordingly, investors in the Partnership must be prepared to assume the risks inherent in such speculative investments. An investment in the Partnership should not be regarded as a complete investment program and should be considered solely by investors prepared to experience possible short-term volatility and fluctuations in value in the interest of seeking superior long-term capital appreciation. Equity Risks. The Partnership may invest in equity and equity derivative securities, including exchange traded funds and index based products. The value of these securities generally will vary with the performance of the issuer and movements in the equity markets. As a result, the Partnership may suffer losses if it invests in equity securities of issuers whose performance diverges from the Investment Manager’s expectations or if equity markets generally move in a single direction and the Partnership has not hedged against such a general move. To the extent the Partnership invests in equity derivatives and private placements activities, the Partnership will be exposed to risks that issuers will not fulfill their contractual obligations to the Partnership, such as delivering marketable common stocks upon conversions of convertible securities and registering restricted securities for public resale. Concentration of Investments. The Partnership’s investment portfolio may, at times, be confined to the securities of relatively few issuers. Any concentration necessarily increases the degree of Partnership exposure to a variety of issuer-related, industry or market risks. By concentrating investments in a small number of large security positions relative to Partnership capital, a loss in any such position could materially reduce the Partnership’s performance asset base, to the extent not offset by other gains. Short Selling. Short selling is a part of the Investment Manager’s investment strategy and may be utilized both in situations where the Investment Manager believes the securities in question are overvalued, and therefore likely to experience significant price declines over time, or as a hedge or offset to related long positions. Short selling inherently involves certain additional risks. Selling securities short creates the risk of losing an amount greater than the initial investment in a relatively short period of time and the theoretically unlimited risk of an increase in the market price of the securities sold short. There is also the risk that the securities borrowed by the Partnership in connection with a short sale would need to be returned to the securities lender on short notice. If the request for return of securities occurs at a time when other short sellers of the security are receiving similar requests, a “short squeeze” can occur, and the Partnership might be compelled, at the most disadvantageous time, to replace borrowed securities previously sold short with purchases on the open market, possibly at prices significantly in excess of the proceeds received earlier. In addition, short selling can involve significant borrowing and other costs which can reduce the profit or create losses in particular positions.

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There are other inherent difficulties and challenges in short selling. The general negative misperceptions about short-sellers may limit the Investment Manager’s access to management of various issuers and impede its research efforts. Management and other stakeholders of issuers may take legal action against short-sellers to prevent or discourage the legal short sales of the issuer’s securities to avoid depressing the value of its securities. The Investment Manager and the Partnership could be subject to such private legal actions. The cost of, and management time committed to, defending any such action(s) could be substantial. Price Volatility. Stocks are inherently volatile. Such volatility may result in the value of the Partnership’s assets fluctuating from time-to-time more greatly than that of other investment vehicles which may be more diversified. There can be no assurance that the Investment Manager’s investment strategy, including its hedging techniques, or other investment strategies or techniques, will be effective in protecting the Partnership from such price volatility. Investments With Limited or No Liquidity. The Partnership may take significant positions in particular securities which are relatively large as compared to their trading volume or overall market capitalization. Such positions may at times prove more difficult to sell in a timely or efficient manner and could thus impair to some extent the Partnership’s ability to fully realize portfolio gains or limit losses. The Investment Manager does not intend to generally limit investments to issues of any particular minimum capitalization and may, in fact, focus upon smaller capitalization stocks when such securities appear to afford greater appreciation potential. Such stocks often have less liquidity than large capitalization issues. Options. The Partnership may utilize options in furtherance of its investment strategy primarily for hedging certain risks but also for speculative purposes. Options positions may include long positions, where the Partnership is the holder of put or call options, as well as short positions, where the Partnership is the seller (writer) of an option. Although option techniques can increase investment return, they can also involve a relatively higher level of risk. The writing (selling) of uncovered options involves a theoretically unlimited risk of a price increase or decline, as the case may be, in the underlying security. The expiration of unexercised long option positions effectively results in loss of the entire cost or premium paid for the option. Option premium costs, as well as the cost of covering options written by the Partnership, can reduce or eliminate position profits or create losses as well. The Partnership’s ability to close out its position as a purchaser of an exchange-listed option is dependent upon the existence of a liquid secondary market on option exchanges. On occasion the Partnership may also utilize options, particularly in foreign markets, which may have limited liquidity. The seller (“writer”) of a call option which is covered assumes the risk of a decline in the market price of the underlying security or other instrument below the purchase price of the underlying instrument, less the amount of premium received by the seller, and forgoes the opportunity for gain on the underlying instrument above the exercise price of the option. The buyer of a call option assumes the risk of losing its entire investment (the premium paid) in the call option. If the buyer of a call option sells short the underlying security or other instrument, a loss on the call option itself may be offset, in whole or in part, by any gain on the short sale of the underlying position. The seller (“writer”) of a put option which is covered assumes the risk of an increase in the market price of the underlying security or other instrument above the sales price (in establishing the short position) of the underlying instrument, plus the premium received by

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the seller, and forgoes the opportunity for gain on the underlying instrument below the exercise price of the option. The buyer of a put option assumes the risk of losing its entire investment (the premium paid) in the put option. If the buyer of a put option holds a long position in the underlying security or other instrument, a loss on the put option itself may be offset, in whole or in part, by any gain on the underlying position. Leverage; Interest Rates; Margin. As discussed above, the Investment Manager expects to utilize leverage, on behalf of the Partnership, on a moderate basis, as the Investment Manager considers appropriate, primarily for investment purposes to increase investment positions or to make additional investments. Leverage may be employed by means of conventional margin arrangements, or through options, swaps, forwards and other derivative instruments (i.e., so called “synthetic” leverage). While leverage (including the use of derivatives) presents opportunities for increasing the Partnership’s total return, it has the effect of potentially increasing losses as well. Accordingly, any event that adversely affects the value of an investment, either directly or indirectly, could be magnified to the extent that leverage is employed. The effect of the use of leverage by the Partnership in a market that moves adversely to the investments of the entity employing the leverage, could result in a loss to the Partnership that would be greater than if leverage were not employed by the Partnership. In addition, to the extent that the Partnership borrows funds, the interest cost at which the Partnership can borrow will affect the operating results of the Partnership. The use of short-term margin borrowings by the Partnership may result in certain additional risks to the Partnership. For example, should the securities that are pledged to brokers to secure the Partnership’s margin accounts decline in value, or should brokers from which the Partnership has borrowed increase their maintenance margin requirements (i.e., reduce the percentage of a position that can be financed), then the Partnership could be subject to a “margin call,” pursuant to which the Partnership must either deposit additional funds with the broker or suffer mandatory liquidation of the pledged securities to compensate for the decline in value. The broker will typically have the right to liquidate the Partnership’s portfolio in certain circumstances. In the event of a precipitous drop in the value of the assets of the Partnership, the Partnership might not be able to liquidate assets quickly enough to pay off the margin debt and might suffer mandatory liquidation of positions in a declining market at relatively low prices. Similar risks may arise in connection with longer-term borrowings and certain derivative transactions. See “Derivatives” below. Derivatives. The derivatives markets are frequently characterized by limited liquidity, which can make it difficult as well as costly to close out open positions in order to either realize gains or to limit losses. Additionally, many derivatives are valued on the basis of dealers’ pricing of these instruments. However, the price at which dealers value a particular derivative and the price which the same dealers would actually be willing to pay for such derivative should the Partnership be required to sell such position, may be materially different. Such differences may have a materially adverse effect on the Partnership if it is required to sell derivative instruments in order to raise funds for margin purposes or to pay withdrawals. The pricing relationships between derivatives and the underlying instruments on which they are based may not conform to anticipated or historical patterns, resulting in unanticipated losses.

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The stability and liquidity of forwards, swaps, repurchase agreements, and other over-thecounter derivative transactions depend in large part on the creditworthiness of the parties to the transaction. If there is a default by the counterparty to a transaction, the Partnership may have contractual remedies pursuant to the agreements related to the transaction; however, exercising such contractual rights may involve delays or costs, or may not be successful, which could adversely affect the Partnership. It is possible that in the event of a counterparty credit default, the Partnership may not be able to recover all or a portion of its investment in such derivative instrument and may be exposed to additional liability (i.e., the obligations associated with what has become an unhedged position). Foreign Investments. A portion of the Partnership’s assets may consist of foreign investments, which may include foreign or domestic equity securities denominated in foreign currencies and/or traded outside of the United States. Such investments require consideration of certain risks typically not associated with investing in U.S. securities or property. Such risks include, among other things, trade balances and imbalances and related economic policies, unfavorable currency exchange rate fluctuations, imposition of exchange control regulation by the United States or foreign governments, United States and foreign withholding taxes, limitations on the removal of funds or other assets, policies of governments with respect to possible nationalization of their industries, political difficulties, including expropriation of assets, confiscatory taxation and economic or political instability in foreign nations. There may be less publicly available information about certain foreign companies than would be the case for comparable companies in the United States and certain foreign companies may not be subject to accounting, auditing and financial reporting standards and requirements comparable to or as uniform as those of United States companies. Securities markets outside the United States, while growing in volume, have for the most part substantially less volume than U.S. markets, and many securities traded on these foreign markets are less liquid and their prices more volatile than securities of comparable U.S. companies. In addition, settlement of trades in some non-U.S. markets is slower, less systematic and more subject to failure than in U.S. markets. There also may be less extensive regulation of the securities markets in countries other than the United States. Transaction Execution and Costs; Brokerage Allocation. Although the Investment Manager will seek to utilize brokerage firms which will afford superior execution capability to the Partnership, there is no assurance that all of the Partnership’s transactions will be executed with optimal quality. In addition to seeking broker-dealers with superior execution capability, the Investment Manager may allocate transactions to brokers which agree to pay all or a part of certain research-related expenses of the Partnership, the Investment Manager and/or its affiliates, or so-called “soft dollar” arrangements. Although the Investment Manager will, in general, seek such arrangements only where it believes the same will be consistent with principles of best execution, such soft dollar arrangements may result in increased commission costs or other inefficiencies in execution. There can be no assurance that the Investment Manager will be successful in seeking to reduce the expenses of the Partnership through satisfactory soft dollar arrangements or that such arrangements will not result in increased transaction costs or otherwise impact the Partnership. Limitations on Shorting and Hedging Strategies. The Investment Manager may employ certain hedging techniques. Hedging against a decline in the value of a portfolio position does not eliminate fluctuations in the values of portfolio positions, or prevent losses if the values of such positions decline, but establishes other positions designed to gain from those same developments, thus moderating the decline in the overall portfolio value. Such hedge

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transactions, however, also limit the opportunity for gain if the value of the portfolio position should increase. In addition, the degree of correlation between price movements of the instruments used in a hedging strategy and price movements in the portfolio position being hedged may vary. Insufficient correlation between hedged and hedging positions may not only result in failing to protect the Partnership against the risks sought to be hedged but may actually increase the magnitude of overall loss in the event of losses in the hedging positions. For a variety of reasons, the Investment Manager may not seek or be able to establish a sufficiently accurate correlation between such hedging instruments and the portfolio holdings being hedged. Moreover, the Investment Manager may not necessarily endeavor to hedge the Partnership portfolio whatsoever. In the event hedging is utilized, it will be employed, in general, solely as a technique to limit certain market risks. As a general matter, the Partnership’s portfolio will still be exposed to basic issuer risk and other risks attendant to its investment strategy and to particular positions, which risks will not be generally hedged. Overall Investment Risk. All securities investments risk the loss of capital. The nature of the securities to be purchased and traded by the Partnership and the investment techniques and strategies to be employed by the Investment Manager may increase this risk. Many unforeseeable events, including, but not limited to, actions by various government agencies and domestic and international economic and political developments, may cause sharp market fluctuations which could adversely affect the Partnership. Various sectors of the global financial markets have recently experienced extended periods of market volatility, such as disruptions in global supply chains, natural disasters due to climate change, high inflation, and other geopolitical conditions that continue to disrupt global markets having an adverse effect on the financial markets domestically and globally. Consumer and business confidence could increase market volatility and reduce liquidity, which could cause a materially adverse effect on the Firm’s performance and overall ability to achieve its investment strategies. There can be no assurance that the investments or investment techniques employed by the Partnership will achieve the Partnership’s investment objective or that the Partnership will ever be profitable. There can be no assurance that the Partnership will not incur losses.

Item 9. Disciplinary information

To the best of our knowledge, there are no legal or disciplinary events that are material to an Investor's or prospective investor's evaluation of our advisory business or the integrity of our management.

Item 10. Other financial industry activities and affiliations

Neither we nor our management persons are registered as broker-dealers, and neither of us has any application pending to register with the SEC as a broker-dealer or registered representative of a broker-dealer, respectively. Infinitum Asset Management, LLC is affiliated with other Infinitum investment advisers, including General Partners and equivalent entities formed from time to time and subject to the Advisers Act pursuant to Infinitum’s registration in accordance with SEC guidance. There is currently one General Partner in which Inifinitum is affiliated with, however, Infinitum may develop other affiliations during the course of their business. This General Partner is Inifintum Partners GP, LLC, a Delaware limited partnership. These affiliated investment advisers

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operate as a single advisory business together with the Adviser and serve as managers or general partners of private investment funds and other pooled vehicles and generally share common owners, officers, partners, employees, consultants or persons occupying similar positions.

Item 11. Code of ethics, participation in client transactions and personal trading

Code of Ethics Infinitum has adopted a “Code of Ethics” that establishes the high standard of conduct that we expect of our employees and procedures regarding our employees’ personal trading of securities. Our employees are required to certify their adherence to the terms set forth in the Code of Ethics upon commencement of employment and annually thereafter. Employees also are required to provide quarterly certifications of compliance with certain Code of Ethics provisions. The foundation of our Code of Ethics is based upon the following underlying fiduciary principles:

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Employees must at all times place the interests of the Funds and Investors first; Employees must ensure that all personal securities transactions are conducted consistent with the Code of Ethics’ Employee Personal Investment Policy (described below); and Employees should not take inappropriate advantage of their position at the Firm.

The Code of Ethics places restrictions on personal trades by employees and mandates that employees disclose their personal securities holdings and transactions to the Investment Adviser on a periodic basis. The Code of Ethics permits personal accounts but prohibits purchasing or selling securities that appear on the Firm’s Restricted List. Employees are prohibited from participating in Initial Public Offerings (“IPOs”) and entering into Limited Offerings (or private placements) without pre-approval from the CCO. Employees are also prohibited from personally, or on behalf of a Client, purchasing or selling securities that appear on the Firm’s Restricted List. Employees must obtain pre-approval from the CCO before: (i) engaging in any outside business activities; or (ii) making any private investments. We will provide a copy of our Code of Ethics to our Investors, or any prospective investor, upon request, to be viewed on the premises.

Item 12. Brokerage practices

Infinitum is authorized to determine the broker-dealer to be used for executing securities transaction for the Funds. In selecting broker-dealers to execute transactions, we do not need to solicit competitive bids and do not have an obligation to seek the lowest available commission cost. It is not our practice to negotiate “execution only” commission rates; therefore, the Funds may be deemed to be paying for research, brokerage or other services provided by the broker which are included in the commission rate.

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Read the rest of Item 12 (346 more words)

We shall also have the authority to select and appoint custodians of the assets of the Funds. The Firm’s authority is limited by its own internal policies and procedures and each Fund’s investment guidelines. Best Execution In selecting an appropriate broker-dealer to effect a client trade, we seek to obtain “Best Execution,” meaning generally the execution of a securities transaction for a client in such a manner that a client’s total costs or proceeds in the transaction are most favorable under the circumstances. Accordingly, in seeking Best Execution, we will take into consideration the price of a security offered by the broker-dealer, as well as a broker-dealers’ full range and quality of their services including, among other things, their facilities, reliability and financial responsibility, execution capability, commission rates, responsiveness to us, brokerage and research services provided to us (for example, research ideas, analysis, and investment strategies), special execution and block positioning capabilities, clearance, and settlement and custodial services. Soft Dollars The Firm may use “Soft Dollars”. In such cases, Soft Dollar credits, generated by the Fund’s trading activities, would be used to purchase brokerage and research services or products that would otherwise have been Fund expense. We intend to keep any such arrangements within the parameters of the safe harbor of Section 28(e) of the Exchange Act. Neither Infinitum nor any related person receives client referrals from any broker-dealer or third party. However, subject to best execution, we may consider, among other things, capital introduction and marketing assistance with respect to Investors in the Funds in selecting or recommending broker-dealers for the Funds. The provision by a broker of research and other services and property to us creates an incentive for us to select such broker since we would not have to pay for such research and other services and property as opposed to solely seeking the most favorable execution for a client. Any research, services or property provided by a broker may benefit any client and such benefits may not be proportionate to commission dollars related to the provision of such research, services or property.

Item 13. Review of accounts

Our Portfolio Manager and investment professionals continuously monitor and analyze the transactions, positions, and investment levels of the Fund to ensure that they conform with the investment objectives and guidelines that are stated in the Fund’s Offering Documents. In these reviews, the Firm pays particular attention to any changes in the investment’s fundamentals, overall risk management and changes in the markets that may affect price levels. Account Reporting We perform various periodic reviews of each client’s portfolio. Such reviews are conducted by our officers.

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We will distribute an audited financial report with respect to the previous fiscal year to all Investors within 120 days of fiscal year end. We may also distribute quarterly unaudited net asset value statements, quarter-end performance reports, and a quarterly investor letter to all Investors.

Item 14. Client referrals and other compensation

We do not receive economic benefits from non-clients for providing investment advice and other advisory services. Neither we nor any of our related persons, directly or indirectly, compensate any person who is not a supervised person for client referrals.

Item 15. Custody

We will be deemed to have custody of Client funds and securities because we have the authority to obtain Client funds or securities, for example, by deducting advisory fees from a Client's account or otherwise withdrawing funds from a Client's account. Account statements related to the Clients are sent by qualified custodians to Infinitum. We will comply with Rule 206(4)-2 of the Investment Advisers Act of 1940, as amended (the “Advisers Act”) (i.e., the ”custody rule”) by meeting the conditions of the pooled vehicle annual audit approach. Upon completion of the relevant Fund’s annual audit by an independent auditor that is registered with, and subject to inspection by, the Public Company Accounting Oversight Board (PCAOB), we will distribute the Fund’s audited financials to Investors within 120 days of such Fund’s fiscal year end.

Item 16. Investment discretion

We will have full discretionary investment authority with respect to the Funds, including authority to make decisions with respect to which securities to be bought and sold, as well as the amount and price of those securities.

Item 17. Voting client securities

In compliance with Rule 206(4)-6 of the Advisers Act (i.e., the “proxy voting rule”), we have adopted proxy voting policies and procedures. The general policy is to vote all proxy proposals, amendments, consents or resolutions (collectively, “Proxies”) in a prudent and diligent manner that will serve the applicable Client’s best interests and is in line with the Client’s investment objectives. We may take into account all relevant factors, as determined by us in our discretion, including, without limitation:

the impact on the value of the securities or instruments owned by the relevant client and the returns on those securities; the anticipated associated costs and benefits; the continued or increased availability of portfolio information; and industry and business practices.

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Read the rest of Item 17 (97 more words)

Generally, clients may not direct our vote in a particular solicitation. Clients may obtain a copy of our Proxy voting policies and our Proxy voting record upon request. Form N-PX The SEC requires “institutional investment managers” to report “say-on-pay” votes on amended Form N-PX when voting on the approval of executive compensation, the frequency of such executive compensation, and “golden parachute” compensation in connection with a merger or acquisition. If Infinitum files Form 13F during the course of a calendar year, it will have an obligation to annually report say-on-pay voting decisions through amended SEC Form N-PX.

Item 18. Financial information

We are not required to include a balance sheet for our most recent fiscal year, are not aware of any financial condition reasonably likely to impair our ability to meet contractual commitments to Clients, and have not been the subject of a bankruptcy petition at any time during the past ten years.

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Form ADV Part 2A, via the SEC Investment Adviser Public Disclosure site.