November 16, 2007 by FINalternatives

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  Friday, November 16, 2007


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                                                                               www.finalternatives.com
                                                                                                                &       PRIVATE                           EQUITY                         NEWS
                                                                                                                                                                               Vol. III, No. 44


                                                                                                                                                          Inside this Issue
Launches Credit Fund                                                                                                                           News ..................................... 2, 6, 13
                                                                                                                                               Bear Gets The Boot

P   aris-based Tikehau Investment
    Management has launched a
private equity fund designed to
                                                                      instruments trying to benefit from
                                                                      the market dislocation that we’re
                                                                      seeing at the moment,” he says.
                                                                                                                                               Emerging Markets, Equity Long/Short
                                                                                                                                                  Have Strong October
                                                                                                                                               RAB Buys Stake In Japanese Asset
take advantage of the current credit                                  “It’s an opportunistic fund trying                                          Manager
                                                                                                                                               Fund Launches ........................... 3-5
crunch. The new fund, TSS, held                                       to source and buy cheap assets and                                       Trinium Closes Fund, Opens Another
a first close at $145 million last                                    hold them through better times.”                                         Goldman Funds Take Aim At Credit
month, and is expected to hard                                           The five-year closed-end fund                                         Pamplona Adds Two Funds
close within the next few months at                                   has a two-year investment period                                         Halls of Justice ........................... 7-8
$500 million.                                                         and charges a 1.5% management                                            Amaranth Sues JPMorgan
                                                                                                                                               Mass. Hits Bear For Fraud
   TSS is a multi-strategy credit                                     fee and 20% carried interest with a                                      Cornerstone, CEO Guilty Of Fraud
fund, which will invest in bank                                       6% hurdle rate.                                                          Shareholder Acitivism .............. 9-10
loans, corporate debt, structured                                        Tikehau manages some $300                                             Hedge Fund Wants To Fly The
credit, asset-backed securities, real                                 million in total assets. Earlier this                                       Friendly Skies
estate and other debt or debt-related                                 year, it launched its first hedge fund,                                  Tepper To Face The (Delphi) Music
                                                                                                                                               Japan Stays Activist Unfriendly
instruments in an opportunistic                                       the $53 million long/short credit                                        Searches and Mandates.............. 11
way, according to founder Bruno                                       offering, Tikehau Credit Oppor-                                          South Carolina Goes With GAM
Pampelonne.                                                           tunities Fund, which returned 6%                                         Private Equity............................... 12
   “The fund will invest in struc-                                    within the last two months, bringing                                     KKR Profit Up, Blackstone Profit Down
                                                                                                                                               People Moves............................... 14
tured and non-structured credit                                       its year-to-date losses to 2%.


Miami Firm Goes South For Maiden Hedge Fund Launch
W      hen Miami-based Thomas
       J. Herzfeld Advisors looks
at the Caribbean—specifically
                                                                      attract some $100 million for the
                                                                      long/short equity fund by then.
                                                                         Havana will invest in equities of
                                                                                                                                            July 1994, according to Erik Her-
                                                                                                                                            zfeld, head of alternative strategies
                                                                                                                                            at the firm. “The closed-end fund
Cuba—it sees the last bastion of                                      exchanges domiciled in Caribbean                                      is an onshore product and geared
emerging markets. The firm is                                         basin countries, hedging its macro                                    towards retail investors, but we
launching a pan-Caribbean hedge                                       exposure with short index posi-                                       got a lot of calls from institutional
fund to capitalize on opportunities                                   tions. It will also allocate a portion                                investors curious if we were going
that it says will be as abundant as                                   of its portfolio to fixed-income and                                  to offer other vehicles,” he said.
the region’s golden sand beaches.                                     private placements, which will be                                        Herzfeld said the firm is
   TJH, which advises and manages                                     put into side pocket allocations.                                     “enthralled” with the Caribbean
closed-ended funds, is prepping                                          TJH currently manages a closed-                                    region and thinks that Cuba, which
Havana Partners for launch within                                     end sister fund of the new hedged                                     has been the subject of a U.S. trade
the first quarter. The firm hopes to                                  offering that has been trading since                                                              Continued on Page 5


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    British Investors Dump Bear, U.S. Clients Vote Today

O     n Wednesday, British inves-
      tors in a collapsed Bear
Stearns hedge fund stymied the
                                               during the subprime credit crunch
                                               this summer, as well as why the
                                               feeder invested in the master fund
                                                                                         court to allow it to dissolve the fund
                                                                                         and liquidate its assets.
                                                                                            “The partnership can no longer
firm’s attempt to liquidate it by              in the first place.                       operate in the manner contem-
replacing Bear as controlling party.              Today, the investors in the over-      plated,” Bear said in its filing in
Will history repeat itself in New              seas fund’s U.S.-domiciled sister         Delaware Chancery Court. It wants
York today?                                    feeder fund will have the chance          to name KPMG—the liquidator of
   In a half-hour meeting at Bear’s            to dump Bear as the fund’s general        the master fund, as well as the pro-
London office, investors in a                  partner at a meeting in New York.         posed liquidator for the overseas
feeder fund, the Bear Stearns High-            That vote was originally scheduled        fund—to do the job.
Grade Structured Credit Enhanced               for Nov. 7, but was postponed after          The master fund, which is domi-
Leverage (Overseas) funds, voted               reports emerged that not all inves-       ciled in the Cayman Islands, is
to oust Bear Stearns Asset Man-                tors had been notified.                   already in bankruptcy proceedings
agement as controlling party and                  The directors of the overseas          there.
replace it with forensic accounting            fund sought to preempt yesterday’s           The proposal to get rid of Bear
firm FTI Capital Advisers. More                vote by seeking two weeks ago to          needs just a simple majority to pass,
than 55% of investors voted to                 place the fund into voluntary liq-        but investors representing more
ditch Bear.                                    uidation. In spite of the success of      than half of the fund’s initial capital
   FTI will use its control over the           that vote, Bear is taking a similar       must be present within a half-hour
fund to investigate how the master             approach with the U.S. feeder. The        of the meeting’s start time. If they
fund lost essentially all of its value         firm on Tuesday asked a Delaware          are not, Bear can cancel the vote.


      FINalternatives                          Morgan Stanley Buys Traxis Stake
          Deirdre Brennan
                Publisher
     dbrennan@finalternatives.com
                                               M      organ Stanley has taken a
                                                      stake in another hedge fund—
                                               its sixth in the past two years—and
                                                                                         funds, and Morgan Stanley is also
                                                                                         expected to invest additional cap-
                                                                                         ital in the funds.
            212.966.0047
                                               one run by a familiar face.                  A year and a half ago, Morgan
             Hung Tran                            The Wall Street giant has bought       Stanley bought Boston-based
           Managing Editor                     less than 20% of New York-based           hedge fund manager Oxhead Cap-
       htran@finalternatives.com                Traxis Partners, which was                ital Managament. It was the first
             212.966.0116
                                               founded by the outspoken Barton           acquisition in a shopping spree that
           Jonathan Shazar                     Biggs four years ago after he left        saw the firm buy stakes in three
            Senior Reporter                    his post as Morgan Stanley’s chief        hedge fund managers in three days
      jshazar@finalternatives.com               strategist.                               in October and November 2006,
             212.966.0051
                                                  Terms of the deal, revealed in a       and another in December..
      Stone Street Media, LLC                  letter to Traxis clients, were not dis-      Morgan bought 18% of Avenue
     262 Mott Street, Suite 102A               closed. Morgan Stanley and Traxis         Capital Group and acquire
     New York, New York 10012                  have been in talks about a minority       the whole of FrontPoint Part-
      www.finalternatives.com
                                               investment since at least the end of      ners, both based in New York, in
    FINalternatives is a general circulation   the summer.                               October 2006, and a 19% stake in
    weekly. No statement in this issue is
    to be construed as a recommendation
                                                  Traxis, a global macro shop,           London-based Landsdowne Part-
    to buy or sell securities or to provide    manages more than $1.5 billion. It        ners in November. In December,
    investment advice. Copyright 2007
    by Stone Street Media, LLC. Copying        is reportedly up 23% year-to-date.        it acquired New York-based long/
    prohibited without the permission of the      Traxis will reportedly put             short credit shop Brookville Cap-
    publisher.
                                               most of the proceeds into its own         ital Management.


2                                                         FINalternatives                                       Nov. 16, 2007
                                                                                           FUND LAUNCHES
Cogent Preps                             Trinium Closes One Hedge Fund,
Long/Short                               Preps Another In Its Place
Hedge Fund

F   airfield, Conn.-based Cogent
    Asset Management is prepping
                                       W      hen one door closes, another
                                              opens, or so goes the cliché.
                                       New York-based Trinium Capital
                                                                                 which managed under $10 million
                                                                                 at the time of closing. “Trinium had
                                                                                 no performance issues, it did well,”
the Madison Street Opportunities       Management, a long/short equity           a source close to the firm said..
Funds to launch on Jan. 1. The         shop founded last July, is trying            The new fund will invest in
onshore and offshore hedge funds       to prove the old saw, closing its         the same core position as its pre-
will employ a value-oriented long/     Trinium Fund because of the depar-        decessor offering but in a purely
short equity strategy.                 ture of partner Chris Harvey. In its      fundamental fashion. “In the past,
   Concurrently, the firm is soft      place, the firm is readying a more        there was a quantitative overlay to
closing its existing long/short        fundamental long/short offering for       Trinium’s fundamental strategy but
hedge funds, Madison Street Fund       a January launch, securing a com-         this will be purely fundamental,”
LP, Madison Street Fund QP, and        mitment from a “substantial” seed         sources said. The firm, which is
Madison Street Portfolio, because      investor to the tune of more than         also changing its name, is also
of “the way the markets have           $15 million, according to sources         planning to hire an analyst for the
resulted in a high amount of cash,     with knowledge of the situation.          new offering.
and the new strategy is going to          Sources said Harvey, Trinium’s            CEO Mike Benevento, who pre-
have larger position sizes with less   former chief strategist and risk          viously ran the media and telecom
opportunistic trading, or short-term   officer, left the firm on Oct. 31 for     portfolio in a core group of funds at
trading, so they’ll hold less cash,”   State Street Bank, resulting in the       Art Sandberg’s Pequot Capital,
said founding principal Glen           decision to shutter his hedge fund,       set up Trinium in early 2006.
Beigel.
   Beigel said the firm hasn’t set
a target for the new funds because
it wanted to put together prod-
ucts with higher capacities than         Goldman Doubles Down On Credit
its existing offerings that couldn’t
accommodate large funds of funds
groups.
   The firm currently manages
                                       G    oldman Sachs CEO Lloyd
                                            Blankfein said the firm has raised
                                       one hedge fund and plans another to
                                                                                 others in the space,” Blankfein
                                                                                 said, referring to the widely-publi-
                                                                                 cized losses in its flagship Global
some $250 million in total assets      capitalize on the credit crunch.          Alpha fund, as well as its Global
in hedge funds and managed                Blankfein said Goldman has             Equity Opportunities and North
accounts. Its flagship $104.5 mil-     raised $2.7 billion for credit hedge      American Equity Opportunities
lion Madison Street Fund has a         fund Liberty Harbor and expects           funds. “While direct quantitative
45-month track record with an          to launch a long/short hedge fund         hedge funds represent only 5% of
annualized return of over 20%          soon. Both are designed “to take          our assets under management, we
with a standard deviation under        advantage of distressed opportu-          realized it would be prudent to fur-
5%, according to the firm.             nities in the credit markets,” he         ther expand our product portfolio
   The Madison Street Opportuni-       told the Merrill Lynch Banking &          in actively-managed strategies.”
ties Funds charge a management         Financial Services Conference.               The long/short fund, expected to
fee of 1.5% and an incentive fee of       “As you know, we’ve had issues         launch in the next few months, is
20% with a minimum investment          with the performance of certain           to be managed by traders who ran a
requirement of $1 million.             of our quantitative funds, as have        similar fund at Goldman.


Nov. 16, 2007                                     FINalternatives                                                   3
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                                                                                            FUND LAUNCHES
Stillwater, Matrix                        Pamplona Adds Real Estate,
Debut ABL Fund                            Energy/Transport Funds
Of Hedge Funds

U    .K.-based Matrix Group and
     Stillwater Capital in New
                                        P    amplona Capital Manage-
                                             ment is beefing up its lineup,
                                        launching a real estate fund of
                                                                                  investors the ability to gain expo-
                                                                                  sure to strong global trends and
                                                                                  leverages off our internal experi-
York recently launched an onshore       hedge funds and is taking over an         ence and expertise.”
version of their new Stillwater         energy and transportation fund.              John Halsted, managing partner
Matrix Fund, a fund of hedge                The $3.5 billion London-based         of Pamplona’s private equity busi-
funds that will invest in about 50      firm on Nov.1 launched the Pam-           ness, will join Pamplona REIF’s
underlying asset-backed lending         plona Real Estate and Infrastructure      investment committee.
strategies.                             Fund of Funds with $30 million.              Pamplona is also adding an
   The offshore fund launched           The fund aims to provide investors        energy and transportation hedge
in August and has already raised        with exposure to the developed and        fund, formerly managed by Lan-
$60 million in partner capital. The     emerging markets in the real estate       glade Capital Management.
domestic fund debuted Nov. 1 and        and infrastructure sectors, and will      The firm said that Lars Titland,
the firms aim to raise a total of       target annual returns of between          a former partner at Langlade, is
$300 million between both funds         15% and 20% with a targeted vola-         joining next month to manage the
by early 2008.                          tility of less than 8%.                   rechristened Pamplona Energy and
   Inflows into the new funds of            “The real estate and infrastruc-      Transportation Global Fund. In
funds have been averaging about         ture fund of funds is the second          addition, Langlade founder Fran-
$10 million a month, according          niche fund of hedge funds product         cois Langlade-Demoyen will join
to Jonathan Kanterman, a Still-         to be offered by Pamplona,” said          the firm in January, as a partner
water managing director. “I’d           Alex Knaster, Pamplona’s CEO.             and the chief investment officer of
expect we’ll get to $300 million        “As with the emerging market fund         Pamplona’s fund of hedge funds
pretty quickly,” he said.               of funds, Pamplona REIF offers            business.
   The funds of funds leverage
Stillwater’s expertise in asset-
backed lending and so far have
                                        HERZFELD cont. from page 1
taken stakes in about three dozen       embargo for more than 45 years,           soon means that Herzfeld will be
ABL hedge fund managers.                will open in the near future to for-      placing his bets on other countries,
   Stillwater manages two other         eign investments. “Cuba is one of         including the Dominican Republic
funds of hedge funds, including         the last communist countries and,         and Panama, in sectors such as
the Stillwater New Finance Fund, a      in our view, it is going to be the next   alternative energy and tourism.
fund of asset-backed hedge funds,       one to topple, and there should be           “The Panama Canal is wid-
as well as the $425 million Still-      an incredible amount of opportuni-        ening, so there is going to be a lot
water Asset-backed Fund, a fund         ties there,” Herzfeld says. “I used to    more cargo and shipping coming
of collateralized loans. The funds      run JPMorgan’s currency business          through, and the cheapest form
charge an annual 1% management          in Asia on the derivatives side and       of transportation is rail and ship
fee with a 20% incentive fee.           when we were looking at Vietnam           so you’re going to see a lot more
   Matrix was founded in 1987 and       in 1999 and 2000, and it feels like       tankers go through there in a few
currently has more than £2 billion of   that right now with Cuba.”                years,” he says. “Trinidad is the
assets under management including          But the fact that the Cuban gov-       biggest exporter to the U.S. of liq-
hedge funds, funds of hedge funds       ernment does not appear poised            uefied natural gas so there’s a lot of
and private equity funds.               for any drastic changes anytime           resources in the region.”


Nov. 16, 2007                                      FINalternatives                                                    5
    Emerging Markets Rise, Short Bias Sinks In Oct.

E   merging markets and short-
    biased hedge funds were on
opposite ends of the market in
                                       hedge fund sectors ending October
                                       on a positive note.”
                                         Managed futures, event-driven
                                                                             September’s precipitous 4.94%
                                                                             decline. The strategy is down
                                                                             3.93% year-to-date.
October, according to data from the    multi-strategy and long/short            It was much the same story on the
Credit Suisse Index Co.                equity also posted strong months,     investable side: the Sector Invest
   Overall, the Credit Suisse/         at 4.06% (6.69% YTD), 3.84%           Emerging Markets returned 4.8%
Tremont Hedge Fund Index               (18.54% YTD) and 3.73% (15.15%        on the month, and is up 17.22%
rose 3.16% last month, and is up       YTD), respectively. Multi-strategy    year-to-date. Managed futures did
13.41% year-to-date. Emerging          funds were up 3.02% (11.71%           almost as well, actually outper-
markets was (again) far and away       YTD). Year-to-date, both global       forming its non-investable coun-
the strongest strategy, adding         macro and event-driven funds are      terpart with a 4.45% return (7.08%
5.48% on the month. It is also the     beating the Standard & Poor’s 500,    YTD), and investable long/short
best-performing strategy of the        with the former up 15.82% through     funds added 3.12% (11.9% YTD).
year, returning 20.94% through         October, when it added 2.72%, and        The Sector Invest Short Bias
October.                               the latter returning 14.77% in the    index was the only investable
   “The [Federal Reserve] interest     period after a 2.91% return last      subindex down for the month, as
rate cuts promoted a rally in global   month. The S&P500 is up 10.87%        it dropped 2.94% (down 5.71%
stock markets while treasury notes     year-to-date, and returned 1.59% in   YTD). Year-to-date, however, it
declined, the dollar weakened, and     October.                              has company: The Sector Invest
crude oil rose to a record $95.91        The only strategy in the red—       Fixed-Income Arbitrage index is
a barrel,” CSI President Oliver        both for October and year-to-         down 4.96% through October in
Schupp said. “Overall, this market     date—was dedicated short bias,        spite of a positive 1.06% return last
environment led to the majority of     which fell a further 2.49% after      month.


    Hedge Funds Power Back                                                   RBC Hedge 250
                                                                             Index Up In Oct.
T   he Greenwich Global Hedge
    Fund Index returned 3.01% in
October, representing its strongest
                                       tional trading group surged 4.48%
                                       in October, up 10.76% YTD. Fol-
                                       lowing the Group’s 3.90% Sep-         T  actical hedge fund strategies
                                                                                drove industry returns last
month since January 2006 and the       tember rally, October’s surge marks   month, as the RBC Hedge 250
best performance for the first 10      what may be one of the larger two-    Index returned 2.49%. The invest-
months of the year since 2003.         month recoveries.”                    able benchmark is now up 9.31%
   The GGHFI’s year to date               The specialty strategies group     year-to-date.
of 12.39% is on par with the           returned 3.63%, up 18.36% YTD.           Three of the index’s top four per-
MSCI World Equity Index (YTD           The long/short equity group fol-      forming subindices were in its tac-
12.75%), and ahead of the S&P          lowed, up 2.92% and 13.24% for        tical group, according to data from
500 (YTD 10.86%) and FTSE 100          the year. The market neutral group    RBC Capital Markets. Managed
(YTD 8.06%).                           had its strongest month since Jan-    futures funds added 4.33% last
   “October’s consistency of per-      uary 2006, yielding 2%, up 9.06%      month (11.12% YTD), followed by
formance across strategies has hit     YTD.                                  equity long/short at 3.08% (12.83%
its strongest level since 2003, with      All 18 individual strategies       YTD) and macro at 2.6% (3.39%
all four strategy groups’ returns at   tracked by the GGHFI ended in         YTD).
their highest since January 2003       positive territory and are positive      Mergers and special situations
or before,” notes Ben Rossman,         for the year. The October Index       funds, which rose 3.16% (12.64%
senior vice president. “The direc-     currently includes 988 funds.         YTD) and 2.22% (10.35% YTD)..

6                                                FINalternatives                                  Nov. 16, 2007
                                                                                         HALLS OF JUSTICE
Mass. Sues Bear                         Amaranth Blames JPMorgan For
Over Collapsed                          Collapse, Files Suit
Hedge Funds

W      illiam Galvin, the Mas-
       sachusetts secretary of the
                                      C    ollapsed hedge fund Amaranth
                                           Advisors has filed suit against
                                      JPMorgan Chase, alleging the
                                                                                backed out of the trade.
                                                                                   According to Amaranth, JPM-
                                                                                organ eventually got its wish,
commonwealth and bête noire of        Wall Street bank derailed its efforts     assuming the portfolio along with
the hedge fund industry, has Bear     to save the fund in an effort to profit   Citadel, earning $725 million.
Stearns in his sights.                from Amaranth’s dire straits.                “It is our view that absent
   Galvin sued Bear Stearns Asset         Greenwich, Conn.-based Ama-           JPMorgan’s actions, the fund’s
Management this week, alleging        ranth said in the lawsuit, filed in       losses, though significant, would
that it failed to notify investors    Manhattan this week, that JPM-            have been survivable and far less
and independent directors of two      organ, which served as the hedge          dramatic,” Amaranth CEO Nick
collapsed hedge funds about con-      fund’s clearing broker, refused to        Maounis said in a letter sent to
flicts of interest. The complaint     execute a trade transferring the          investors explaining the lawsuit on
accuses the firm of trading secu-     fund’s disastrous natural gas posi-       Tuesday. Maounis said that $2.5
rities from its own accounts with     tions to Goldman Sachs because            billion of Amaranth’s $6 billion in
the High-Grade Structured Credit      it wanted to take control of the          losses were the result of the cash
Strategies and High-Grade Struc-      portfolio itself. Amaranth said that      concession it had to pay JPMorgan
tured Credit Strategies Enhanced      action, on Sept. 18, 2006, cost it        to take on its energy portfolio.
Leverage funds without letting cli-   several hundred million dollars in           Amaranth is seeking at least $1
ents know in writing and receiving    additional market losses.                 billion in damages.
their consent.                            On the same day, Amaranth said           JPMorgan dismissed Amaranth’s
   “Investors who sought to take      it struck a similar deal with Citadel     story as “an effort to rewrite history,
advantage of the inimitable risk      Investment Group, which agreed            and to blame JPMorgan for losses
management reputation of Bear         to take on two-thirds of the port-        that were the result of Amaranth’s
Stearns found themselves in           folio in exchange for a $1.85 bil-        disastrous trading.”
a highly-complex hedge fund           lion concession payment. But the             “JPMorgan’s        conduct      was
investment program that relied on     complaint alleges that the co-CEOs        entirely appropriate, and consis-
overworked junior personnel to        of JPMorgan’s investment bank,            tent with its rights and obligations
manage a conflict reporting pro-      Steve Black and Bill Winters,             as Amaranth’s future commissions
cess required by federal law,” the    called Citadel founder Kenneth            merchant,” spokeswoman Kristin
complaint says.                       Griffin to warn him that “Ama-            Lemkau said in a statement. “The
   In addition, Galvin said that a    ranth is not as solvent as they are       firm intends to defend this baseless
former director of the funds failed   telling you they are.” Citadel then       lawsuit with the utmost vigor.”
to respond to subpoenas he issued.
   “Investors are entitled to know
when their investment adviser has
                                      Bayou Founder Sentencing Delayed
some stake in the other side of the
deal,” he said in a statement. “The
cavalier attitude that this company
                                      B  ayou Group fraudster James
                                         Marquez’s sentencing on fraud
                                      charges has been postponed.
                                                                                tors of more than $10 million last
                                                                                December. A federal judge in Man-
                                                                                hattan rescheduled his sentencing
had about its various conflicts of       Marquez, who founded the col-          hearing for Tuesday to allow
interests is intolerable.”            lapsed Stamford, Conn.-based              attorney for both sides to settle
   Galvin is seeking unspecified      hedge fund with Samuel Israel,            issues raised by the defense last
damages.                              pleaded guilty to defrauding inves-       week.


Nov. 16, 2007                                    FINalternatives                                                     7
HALLS OF JUSTICE

    New York Hedge Fund Manager Guilty Of Fraud

A    U.S. District Court judge has
     found New York-based hedge
fund Cornerstone Capital Man-
                                        returns, which were inflated to
                                        42.18% in 2005 and 20.74% in
                                        2006. The order found that the
                                                                               which represented that the hedge
                                                                               fund had net assets of $14.8 million
                                                                               as of Dec. 31, 2005, and returns
agement and its CEO, Joseph             fund was never profitable, and that    in excess of 20% between Oct. 1,
Profit, guilty of fraud.                its CEO lost in excess of $1 million   2004 and Dec. 31, 2005.
   The     Commodity         Futures    due to trading losses and personal        Finally, Profit also hid material
Trading Commission announced            withdrawals, which he spent on         information from the National
that the judge has entered a perma-     non-investment activities such as      Futures Association and failed to
nent injunction against the firm. The   meals, golf outings, airline tickets   submit to the NFA a required 2005
ruling stems from a complaint filed     and lodging.                           annual report for the Icon Fund.
by the CFTC on Jan. 31 charging            Profit also inflated the fund’s        The order permanently enjoins
that Cornerstone, a registered com-     assets under management from           Profit from further violations and
modity pool operator and com-           $3.2 million to $50 million when he    requires Cornerstone to pay res-
modity trading adviser defrauded        reported them in various databases     titution and civil monetary pen-
investors in the Icon Fund, a pur-      and to hedge fund information pro-     alties, the amounts of which will
ported hedge fund.                      viders. In addition, the order finds   be determined after the court-
   Profit was found liable for          that he prepared and delivered to at   appointed receivership in the case
defrauding existing and prospec-        least one investor a phony audited     is completed.
tive investors by lying about Icon’s    financial statement for the fund,




8                                                 FINalternatives                                   Nov. 16, 2007
                                                                                 SHAREHOLDER ACTIVISM

  Appaloosa Prez Faces Grilling                                                  Hedge Fund
                                                                                 Pushes Delta,
D    avid Tepper, the billionaire
     president of Appaloosa Man-
agement, is set to be grilled by
                                         holders will only get $69 mil-
                                         lion—a precipitous decline from
                                         the $470 million proposed in the
                                                                                 United Merger
fellow shareholders of auto parts
maker Delphi Corp., which the
                                         initial plan.
                                            Delphi has also sought to amend      D    elta Air Lines and United Air-
                                                                                      lines are a step closer to cre-
                                                                                 ating the world’s largest air courier,
hedge fund plans to pump $2.55           the plan to cut borrowing and cash
billion into as part of a reorganiza-    payments to former parent Gen-          and hedge fund Pardus Capital
tion plan.                               eral Motors.                            Management couldn’t be happier.
   The deposition is part of the            Appaloosa, along with the equity        The $3 billion New York fund
shareholder’s battle to stop bank-       committee, has opposed the plans,       manager sent a letter to both air-
rupt Delphi’s restructuring. Under       but has not withdrawn its August        lines urging them to commence
the plan, the company’s share-           agreement with Delphi.                  merger talks. And although both
                                                                                 denied that talks have begun, Delta
                                                                                 CEO Richard Anderson said
                                                                                 his company has set up a special
Report: Hedge Fund Pressure Leads                                                committee to explore its options,
To 200 Deutsche Börse Layoffs                                                    though he said Pardus’ claim that
                                                                                 Delta must merge or die is “inac-

C    hristopher Hohn is apparently       delsblatt reports. London-based         curate and ill-founded.”
     not satisfied with just one scalp   TCI is pushing Deutsche Börse to           Pardus, which owns 7 million
at the Frankfurt Stock Exchange,         streamline operations and return        Delta shares and 5.6 million shares
according to media reports.              money to shareholders.                  of United parent UAL Corp., said
   The Deutsche Börse is slashing           Two years ago, then-Deutsche         it also considered a Delta merger
200 employees under pressure             Börse CEO Werner Seifert was            with Continental Airlines and
from Hohn’s hedge fund, The              forced out after TCI helped sink the    Northwest Airlines. According to
Children’s Investment Fund, the          exchange’s proposed acquisition of      Pardus, a Northwest merger would
German business newspaper Han-           the London Stock Exchange.              create the greatest net synergies of
                                                                                 $1.5 billion, but could result “in the
                                                                                 need for a potential follow-on trans-
                                                                                 action at a later date.” A Continental
  Billboards Make Biglari’s Point                                                deal would produce no synergies.
                                                                                    The hedge fund said a merged

H    edge funds are not allowed to          Biglari, who controls 7.3% of        Delta and United would result
     advertise, but that’s not stop-     Steak n Shake, says he is annoyed       in $585 million in synergies and
ping Sardar Biglari.                     with the company’s poor perfor-         “more network breadth than any
   The head of San Antonio’s Lion        mance, and announced last month         other transaction.”
Fund put up three billboards in          a proxy battle for a pair of spots on      “We believe it is imperative that
Indianapolis, but don’t expect the       Steak n Shake’s board. And to that      you seek to enter into a merger
Securities and Exchange Com-             end, he’s taking a page out of the      transaction with another carrier
mission to slap him with a cease-        political campaign playbook: The        given the rapid rise in fuel prices
and-desist order. The ads are part       billboards implore Steak n Shake        and the increased risk to the busi-
of Biglari’s very public campaign        shareholders to vote for Biglari and    ness as a stand-alone entity,”
for the board of Steak n Shake, an       Lion Fund board member Philip           Pardus President Karim Samii and
Indianapolis steakhouse chain.           Cooley in the proxy fight.              principal Shane Larson wrote.


Nov. 16, 2007                                      FINalternatives                                                   9
SHAREHOLDER ACTIVISM

    Japanese Court Rebuffs Second                                                                           Third Point
    Activist Hedge Fund                                                                                     Dumps PDL
                                                                                                            Stake
A    Japanese court has rejected a
     British hedge fund manager’s
bid to block a portfolio company’s
                                                         bonds, complaining it gave the
                                                         company away for too little and
                                                         could dilute its 4.6% stake. But the               D    aniel Loeb is flying the white
                                                                                                                 flag.
bond issue, making activist man-                         Tokyo District Court rejected its                     Loeb’s activist hedge fund
agers 0-for-2 in court bids this                         request, filed last week. In August,               shop Third Point has dumped
year.                                                    Steel Partners was also rebuffed                   its remaining stake in PDL Bio-
   Silchester International Inves-                       in its effort to prevent a Japanese                Pharma, selling more than 6
tors had sought to prevent Auto-                         Worcestershire sauce maker from                    million shares of the Fremont,
bacs Seven, a Japanese auto parts                        implementing a poison pill.                        Calif.-based          pharmaceutical
retailer, from issuing 65 billion                           Autobacs said it would go ahead                 between Oct. 30 and Nov. 9.
yen ($589 million) in convertible                        with the bond sale.                                Loeb had unsuccessfully sought a
                                                                                                            board seat, though he said he was
                                                                                                            “encouraged” by the company’s
                                                                                                            decision to seek a sale.
    Hedge Fund Copper River                                                                                    But, in a letter to PDL’s board
                                                                                                            last month explaining why he had
    Countersues Overstock.com                                                                               halved his firm’s stake to 5.1%, he
                                                                                                            ripped board chairman and interim

I t took more than two years, but the
  hedge fund sued by Overstock.
com has finally countersued.
                                                         Overstock of a “campaign of
                                                         menace” using short squeezes to
                                                         distract from its poor performance.
                                                                                                            CEO Patrick Gage for his “unsuit-
                                                                                                            ability” to lead the company—in
                                                                                                            addition to the board’s “continuing
   Larkspur, Calif.-based Copper                            The hedge fund says Overstock                   refusal to provide us with a voice
River Partners, accused by Over-                         altered its accounting system to                   in the company’s affairs through a
stock of being part of a wide-                           allow it to claim a big jump in rev-               board seat.”
ranging conspiracy to drive down                         enues, though there was allegedly                     Loeb sold 4.9 million shares
its stock price, returned fire,                          no corresponding spike in business                 in the last three days of last week
alleging that the online retailer                        activity. It also accuses Overstock                alone.
used a campaign of misinformation                        CEO Patrick Byrne of publicly                         But PDL is not out of the activist
and fudged accounting to jack up                         downplaying the company’s need                     hedge fund woods: As Third Point
its share price.                                         for capital.                                       sold off its entire stake in the com-
   In addition, Copper River—the                            Overstock said there is nothing                 pany, Dallas-based Highland
former Rocker Partners—accuses                           to Copper River’s claims.                          Capital Management has built
                                                                                                            up a 5.2% stake in PDL over the
                                                                                                            past few months, and is calling for
     Spread the word with reprints...                                                                       many of the same changes Third
                                                                                                            Point sought.
                                                 For information about permissions                             “We believe the time for dialogue
                                                        and reprints, please contact                        has ended,” Highland wrote to
                                                 Deirdre Brennan at 212.966.0047                            PDL, demanding it “expeditiously
                                                  or dbrennan@finalternatives.com                            implement our recommendations
     All FINalternatives articles are protected by copyright and cannot be republished or printed, either   in order to protect shareholder
           in hard copy or online, without prior permission from the publisher, Stone Street Media, LLC.
                                                                                                            value.”


10                                                                      FINalternatives                                          Nov. 16, 2007
                                                                                  SEARCHES & MANDATES
South Carolina                             Washington Commits $1.5B To
Pension Invests                            Private Equity Funds
$750 Million With
GAM                                      T  he $63.9 billion Washington
                                            State Investment Board has
                                         approved commitments of up to
                                                                                  billion to US$11.7 billion); up to
                                                                                  $750 million to the $12 billion
                                                                                  Warburg Pincus Private Equity X
G    AM, the $26.8 billion fund
     of hedge fund manager, has
been hired by the South Carolina
                                         $1.5 billion to four private equity
                                         funds focusing on buyouts in the
                                                                                  fund; up to $25 million to the $1.3
                                                                                  billion Advent Latin American Pri-
                                         U.S., Europe and Latin America.          vate Equity Fund IV, which invests
Retirement System to manage a               The system is committing up to        primarily in Mexico, Brazil and
$750 million allocation to its GAM       $700 million to the KKR European         Argentina; and up to $50 million to
Diversity strategy.                      Fund III, a large-cap, pan-Euro-         the Avenue Special Situations Fund
   Diversity is a $10 billion globally   pean buyout fund with a target size      V, a targeted $6 billion distressed
diversified, multi-strategy fund of      of €6 billion to €8 billion (US$8.8      debt fund.
hedge funds that includes between
60 to 80 underlying managers. The
portfolio is split between equity
and arbitrage strategies.                  Ill. SURS Smitten With Adams
   “South Carolina has made a
fairly large entry into reallocating       Street Partners
their assets so for the first time
they’re beginning to work exten-
sively with outside managers,” said
Joe Gieger, a managing director at
                                         T  he $16 billion State Universi-
                                            ties Retirement System of Illi-
                                         nois is committing $100 million
                                                                                  debt and special situations. Typi-
                                                                                  cally, commitments will be invested
                                                                                  over three to four years.
GAM.                                     to the Adams Street Partners 2008           Over the years, SURS has
   South Carolina Retirement’s           Global Offering Program, a private       invested over $1 billion in several
portfolio has undergone drastic          equity fund of funds.                    Adams Street Partners funds. Of
changes since legislation was               The offering will be structured       this amount, $920 million has been
passed last year allowing the            to combine three separate private        distributed back to SURS and as of
system to invest in alternatives.        equity funds, a U.S. fund, a non-        March 31 the market value of its
The pension has allocated 30% of         U.S. fund and a direct fund, into one    investments in Adams Street Part-
its $30 billion to alternative invest-   offering, according to an internal       ners was $500 million.
ments, with 15% of assets going          memo. The new vehicle will invest           “Investment performance with
to portable alpha strategies, 5%         in a portfolio of private equity part-   Adams Street Partners has been
to private equity, 5% to real estate     nerships diversified by time, man-       excellent for SURS. The inception-
and 5% to global asset allocation        ager and subclass such as venture        to-date internal rate of return, net of
strategies.                              capital, buyout, mezzanine/subordi-      fees, for the relationship is 27.5%,”
   The South Carolina system has         nated debt, restructuring/distressed     according to the memo.
reportedly hired about a dozen
absolute-return managers, allo-           FINalternatives will not be published on
cating some $4.5 billion to funds
of hedge funds and multi-strategy
                                          Friday, November 23, due to the
hedge funds, with another $1.5 bil-       Thanksgiving holiday. FINalternatives.com
lion split among four managers in         will not publish on November 22 or 23.
directional hedge funds.                  Have a happy and safe Thanksgiving.


Nov. 16, 2007                                       FINalternatives                                                   11
PRIVATE EQUITY
KKR Profit Up As                              Blackstone Profit Takes Big Q3 Hit
Assets Soar
P   rivate equity giant Kohlberg
    Kravis Roberts, preparing for
                                          T  he Blackstone Group swung to
                                             a third-quarter loss after taking
                                          a big charge relating to its initial
                                                                                     lion from $196.1 million. The firm
                                                                                     said the credit crunch had spread to
                                                                                     the general commercial real estate
an initial public offering, said this     public offering this summer.               lending market.
week that its net income rose 26%            Overall, revenue grew 14% to               “While it will be difficult to
in the first half as leveraged buyout     $526.7 million, as three of its four       structure very large leveraged
activity soared.                          divisions enjoyed revenue spikes,          transactions in corporate private
   KKR said in a filing with the          but an $802.6 million non-cash             equity and real estate until the credit
Securities and Exchange Com-              charge—due to compensation costs           markets improve, pricing of assets
mission that profits rose to $667.4       from IPO unit awards, as well as           is more favorable,” CEO Stephen
million from $529 million in the          amortization of intangibles—sent           Schwarzman said.
year-earlier period, as assets under      the private equity giant to a $113.2          And indeed, all three of its other
management soared 89% to $45.1            million loss in the quarter. The com-      divisions—including         corporate
billion. Strong investment per-           pany said it made a $372.5 million         private equity—enjoyed big gains
formance—investment           income      profit in the year-ago period, when        on the quarter. Corporate private
rose 69% to $3.4 billion during           it was still a private concern.            equity revenue rose 42% to $227.3
the period—offset a decline in fee           Blackstone also said the sub-           million. Asset management rev-
income due to lower transaction           prime mess contributed to the loss,        enue, which includes the firm’s
fees. KKR earned $115.4 million           as its real estate group saw revenue       hedge fund operations, soared 88%
in fees, a 26% drop from last year.       fall by almost half, to $109.1 mil-        to $124.9 million.




                                     Bullish.                      Bearish.




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     Led by economist Nouriel Roubini, our analysts define the key issues, then glean the most significant insights from
     thousands of sources for your review. So you can quickly get up to date – and stay ahead of the curve.



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12                                                   FINalternatives                                        Nov. 16, 2007
Och-Ziff Goes                                 RAB Takes 20% Stake In Japanese
Public, Raises                                Asset Manager
$1.15 Billion
O     ch-Ziff Capital Manage-
      ment raised $1.15 billion in
                                          U    .K.-based alternative asset man-
                                               ager RAB Capital is making a
                                          push into the Japanese investment
                                                                                  uting selective RAB products,” said
                                                                                  Michael Alen-Buckley, RAB Cap-
                                                                                  ital executive chairman. “This stra-
its initial public offering, selling 36   marketplace with the acquisition of     tegic shareholding further deepens
million shares at the high end of its     a 20% stake in Tokyo-based Pres-        our relationship, and reflects the
forecast price range.                     tige Asset Management.                  goal of establishing broader coop-
   Shares of Och-Ziff were priced at         The Japanese firm, which was         eration with Prestige in promoting
$32 a piece, and listed on the New        established in 2004 by former           the RAB offering in Japan.”
York Stock Exchange under the             Goldman Sachs managing director            RAB Capital currently boasts
ticker symbol “OZM.” The stock            Makoto Matsuzaki, focuses on            $7.1 billion of assets under manage-
was forecast to sell for between          investment advisory and distri-         ment. The firm manages 15 abso-
$30 and $33.                              bution of investment products in        lute return strategies with assets in
   The IPO, underwritten by a syn-        Japan.                                  excess of $100 million (13 single
dicate led by Goldman Sachs and              “Makoto Matsuzaki has put            strategy and 2 multi strategy) and
Lehman Brothers—who have                  together an impressive team that has    also manages the AIM-listed RAB
an option to purchase another 5.4         already been successful in distrib-     Special Situations Company.
million shares to cover overallot-
ments—represents 9% of the $30
billion New York-based hedge fund             Icahn Hedge Funds Post 1st Loss
manager.

                                          I t wasn’t exactly Bill Miller’s
                                            storied streak, but Carl Icahn’s
                                          three-year run of positive quarterly
                                                                                     ICM’s returns were “impacted
                                                                                  by volatile market conditions as
                                                                                  well as equity positions related to
Fortress Posts                            returns has come to an end.
                                             Icahn Capital Management
                                                                                  consumer, real estate and financial
                                                                                  sectors that represented losses for
$38M Q3 Loss                              posted $133.7 million in losses,        the quarter,” the firm wrote.
                                          amounting to a 1.5% decline,               Icahn manages more than $7 bil-

F   or the second straight quarter,
    Fortress Investment Group
is in the red, after a special charge
                                          according to a regulatory filing last
                                          week. The majority of the losses
                                          were in investments in homebuilder
                                                                                  lion and had enjoyed average annu-
                                                                                  alized returns of 25.8% until this
                                                                                  past quarter. In spite of the third
wiped out its profit.                     WCI Communities and aircraft            quarter’s slip, the funds are still up
   The New York-based alterna-            maker Lear Corp.                        19.8% through October.
tives giant posted a net loss of $38
million in the third quarter, due
to a non-cash charge of $54 mil-              Cambridge Place Slashes Jobs
lion stemming from its principals’

                                          W
agreement related to the firm’s                  hile many hedge funds            20% of its 120-strong workforce.
initial public offering in February.             burned by the collapse of the    So far, 25 front- and back-office
Fortress turned a $64.7 million           subprime market have recovered in       employees in Boston and London
profit in the year-ago period.            recent months, one of the first the     have lost their jobs.
   Third-quarter revenue soared           feel the heat is still suffering.         London-based Cambridge Place
80% to $219 million as assets                Cambridge Place Investment           has already been forced to shutter
under management declined 8% to           Managers, which manages about           one hedge fund and limit with-
$39.9 billion.                            $9 billion, will reportedly slash       drawals from two others.

Nov. 16, 2007                                       FINalternatives                                                 13
                                        PEOPLE MOVES

Paladyne Appoints                       kets group.
                                           Levenson joins Cowen from
                                                                                Pioneer Adds
New CFO, General                        Houlihan Lokey Howard &                 Three To FoF Re-
Counsel                                 Zukin, where she was a managing
                                        director leading the firm’s private     search Team
                                        equity and private investment in
P   aladyne Systems, a provider of
    tech support for hedge funds,
has appointed Steve Vogel as CFO
                                        public equity placement effort.
                                        Prior to joining Houlihan Lokey,        L  ondon-based Pioneer Alterna-
                                                                                   tive Investments has strength-
                                        Levenson was a senior managing          ened its fund of hedge funds
and general counsel overseeing
                                        director in the strategic finance       research team with a trio of new
finance and administration, legal
                                        group at Bear Stearns and head of       hires.
matters, corporate and project
                                        the firm’s private placement group.        Bob Puccio has joined as
finance, accounting, treasury and
                                                                                global head of macro, quantitative,
human resources.
                                                                                fixed-income and multi-strategy
   Prior to joining Paladyne, Vogel
                                                                                research. Most recently, he was a
founded Sanguinity, a consulting        Ivy Hires Director                      senior hedge fund analyst at Gen-
firm specializing in the restruc-
turing of domestic public and pri-      To Head New Asian                       erali Group’s Thalia.
                                                                                   Pioneer has also hired David
vate companies. He has also held        Operations                              Siegel and Ellen Cooper, the
CFO and general counsel positions
                                                                                former as a junior research analyst

                                        I
at software companies.                    vy Asset Management, a hedge          and the latter as a junior operational
                                          fund of hedge funds and alterna-      due diligence analyst.
                                        tive investment management firm
Cowen Group                             with over $15 billion in assets, has
                                        hired Alex Balfour as managing
Names Private                           director, head of client develop-       Hedge Fund Admin.
Equity Head                             ment, Asia (ex-Japan). Balfour will     Hires Citco Exec.
                                        be based in Hong Kong, where the
                                        firm expects to open its sixth office
T  he Cowen Group has hired
   Julie Levenson as managing
director and head of the firm’s pri-
                                        in the first half of 2008.
                                           Balfour will report to Patrick
                                                                                H    edge fund administrator Ami-
                                                                                     corp Fund Services has
                                                                                named Citco Fund Services vet-
                                        Thomson, managing director, and         eran Claudio Cecchini director of
vate equity group.
                                        will be responsible for both client     funds.
   Over the course of 20 years in
                                        development and managing the               “Claudio will expand the global
investment banking, Levenson has
                                        Hong Kong office.                       management team of Amicorp Fund
completed more than 75 financing
                                           Balfour joins Ivy from Union         Services where his focus will be on
transactions, representing over $3.5
                                        Bancaire Privée, where he was           business development,” Amicorp
billion in financing volume, with
                                        a managing director and head of         CEO Toine Knipping said.
clients that have included Silicon
                                        Asian institutional business. Prior        Cecchini spent 10 years at
Graphics, Leap Frog Enterprises,
                                        to that, he founded Balfour Cap-        Citico before joining Curaçao,
Procom Technology and Aecom
                                        ital, an Asian hedge fund, which        Netherlands Antilles-based Ami-
Technology, among others.
                                        he then ran for eight years. He         corp, which administers some $4
   In her new role at Cowen, she
                                        also spent eight years at Baring        billion. Previously, he worked at
will be based in the firm’s San Fran-
                                        Asset Management as a portfolio         Fortis Prime Fund Solutions in
cisco office and report to Jonathan
                                        manager focused on the Japanese         the Netherlands.
Biele, head of Cowen’s capital mar-
                                        markets.


14                                                FINalternatives                                     Nov. 16, 2007
  North American Hedge Fund League Tables
By Ankur Samtaney, Eurekahedge Analyst


N     orth American hedge funds fared well last month,
      with the Eurekahedge North American Hedge Fund
Index returning 2.6% during the month. In the under-
                                                                              global currencies ( down 1.5% vs the Euro and 5.1%
                                                                              vs the Australian dollar) posed lucrative opportunities
                                                                              for CTAs, who returned a
lying markets, besides equities (especially consumer                          solid 3.3% for the month.
non-cyclical sectors) across the region ending the month                      Multi-strategy managers
fairly well, commodities rallied strongly; gold touched                       also fared well last month
its 27-year high after rallying 6%, and crude oil prices                      (2.8%) cashing in on
surged about 15% (on the back of heightened Middle                            opportunities in equities,
Eastern tensions), during the month. This, coupled                            commodities, fixed income (as yields declined, there-
with further weakening of the U.S. dollar against most                        fore driving prices higher) and currencies.


                                                                                       AuM Oct. ‘07 ‘07 YTD        2006          % rise in   Annualized
 Name of the Fund                                                       Rank2     (US$ Mln) Return return          return        NAV         return
 Eurekahedge North American Hedge Fund Index1                                                    2.60      10.90     12.29          149.89       12.40


 CTA/Managed Futures
 Eurekahedge North America CTA/Managed Futures Hedge Fund Index                                  3.27       9.82      9.66          160.39       13.00


 Singleton Fund LLC                                                          1            17     8.00      50.08     37.75          106.73       58.20
 RAM Fund LLC                                                                2             0   -14.10      29.11     -19.20          93.23        6.99
 Parrot Trading Partners                                                     3             6    14.75      26.69     12.45           79.15       17.67
 Trendline Fund LP                                                           4             2     5.80      17.99     -16.01          41.35        3.27
 RQSI Managed Futures Fund - Leveraged Program                               5          612      4.93      15.63      4.12           50.99        9.78
 Tactical Institutional Futures Program                                      6            35     3.66      13.30     24.26        1,211.04       19.30
 Tactical Multistrategy Commodity Fund LP                                    7            32     2.76      12.57     18.59          202.10       17.11
 Excelsior Aggressive Fund LP                                                8            13     8.45      12.55     12.43          375.04       13.28
 Salem Futures Fund LP                                                       9            98     4.34      11.46      9.22          932.53       14.72
 Excelsior Fund LP                                                         10              4     4.57      11.10      9.83        2,218.45       17.82


 Multi-Strategy
 Eurekahedge North America Multi-Strategy Hedge Fund Index                                       2.83       9.29     14.43          130.41       11.24


 Sorin Fund LP                                                               1         1,333     4.26      25.05      9.72           57.48       15.00
 Atlas Global Investments Ltd                                                2         1,000     6.15      18.72     25.07          504.52       36.13
 Cross Shore Fund Ltd                                                        3            94     2.50      17.78     11.64           73.18       13.51
 Highland Credit Strategies Master Fund                                      4         1,025     6.09      17.42     32.12           65.23       26.08
 Wexford Offshore Spectrum Fund - Class A                                    5         2,052     2.20      17.31     13.78          448.06       17.44
 Huntrise Global Partners Ltd                                                6            32     2.80      15.42     20.44          129.82       13.47
 Harborview Capital Partners LP                                              7            35     1.04      14.69     34.19          134.74       32.90
 Henderson North American Equity Multi-Strategy Fund - USD                   8            60     3.02      12.43      -0.21          20.85        7.87
 Ventura Capital Partners LLC                                                9             7     2.25      10.93     13.16           26.10       12.86
 Oak Group VL I LP                                                         10              6     2.81      10.85      6.93          228.12        7.31

                             1                                                                                              2
                                 based on 58.36% of the funds reporting their September 2007 returns as at Nov. 15, 2007        ranked by 2007 YTD returns



Nov. 16, 2007                                                      FINalternatives                                                                    15

								
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