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EFTA01393408

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GLDUS130 Aspen Grove Capital, LLC Glendower Capital Secondary Opportunities Fund IV. LP has been made or will be made with respect to the solicitation of the application for the acquisition of the Interests, on the grounds that the Interests are securities set forth in article 2, paragraph 2, item 6 of the FIEL and the small number private placement exemption for such securities applies to such solicitation since it does not fall under the category set forth in article 2. paragraph 3. item 3 of the FIEL. No Interests shall be sold in Japan unless at least one qualified institutional investor (a -011") as defined in article 2. paragraph 3. item 1 of the FIEL and article 10 of the cabinet order regarding definitions under article 2 of the FIEL acquires the Interests. No Interest shall be sold to, or held by, persons other than (i) Oils or (ii) persons listed in article 17-12, paragraph 1 of the Order for Enforcement of the Financial Instruments and Exchange Law ('Qualified The number of Qualified Non-Oils in Japan shall not exceed 49. No Interests shall be sold to or held by any person set forth in article 63, paragraph 1, item 1, sub-items (i) to (iii) of the FIEL. No Interests shall be sold to or held by any person where a sale or a transfer of Interests to the person triggers article 234-2, paragraph 2. item 1 or 2 of the Cabinet Office Ordinance regarding Financial Instruments Business, etc., whereby the General Partner of the Fund is unable to rely on the exemption set forth in article 63 of the FIEL. No transfer of the Interests acquired by a QV may be made to persons other than Oils. No transfer of the Interests acquired by a Qualified Non-OIl in Japan may be made except for the transfer by such person of its entire Interests to only one person. The General Partner has an intention to rely on the exemption of Specially Permitted Businesses for Qualified Institutional Investors. etc. set forth in article 63 of the FIEL (so-called, the "Oil-tar

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