SECURITIES AND EXCHANGE COMMISSION 

Investment Company Act Release No. 34966; File No. 812-15423

Alpha Alternative Assets Fund and Alpha Growth Management LLC 

July 27, 2023

AGENCY: Securities and Exchange Commission (“Commission” or “SEC”). 

ACTION: Notice. 

Notice of an application for an order pursuant to section 6(c) of the Investment Company Act of 1940 

(the “Act”) for an exemption from sections 18(a)(2), 18(c), and 18(i) of the Act, pursuant to sections

6(c) and 23(c) of the Act for certain exemptions from rule 23c-3 under the Act, and pursuant to 

section 17(d) of the Act and rule 17d-1 thereunder.

Summary of Application: Applicants request an order to permit certain registered closed-end 

management investment companies to issue multiple classes of common shares of beneficial interest 

with varying sales loads and asset-based service and/or distribution fees and to impose early 

withdrawal charges.

Applicants: Alpha Alternative Assets Fund and Alpha Growth Management LLC.

Filing Dates: The application was filed on January 17, 2023, and amended on May 25, 2023. 

Hearing or Notification of Hearing: An order granting the requested relief will be issued unless the 

Commission orders a hearing. Interested persons may request a hearing on any application by emailing the SEC’s Secretary at Secretarys-Office@sec.gov and serving the Applicants with a copy of 

the request by e-mail, if an e-mail address is listed for the relevant Applicant below, or personally or 

by mail, if a physical address is listed for the relevant Applicant below. Hearing requests should be 

received by the Commission by 5:30 p.m. on August 21, 2023, and should be accompanied by proof 

of service on Applicants, in the form of an affidavit or, for lawyers, a certificate of service. Pursuant 

to rule 0-5 under the Act, hearing requests should state the nature of the writer’s interest, any facts 

bearing upon the desirability of a hearing on the matter, the reason for the request, and the issues 
contested. Persons who wish to be notified of a hearing may request notification by emailing the 

Commission’s Secretary at Secretarys-Office@sec.gov. 

ADDRESSES: The Commission: Secretarys-Office@sec.gov. Applicants: Gobind Sahney, Alpha 

Growth Management LLC, 500 Newport Center Drive, Ste. 680, Newport Beach, CA 92660; 

Andrew Davalla, Thompson Hine LLP, Andrew.Davalla@ThompsonHine.com.

FOR FURTHER INFORMATION CONTACT: Christine Y. Greenlees, Senior Counsel, or Lisa 

Reid Ragen, Branch Chief, at (202) 551-6825 (Division of Investment Management, Chief Counsel’s 

Office). 

SUPPLEMENTARY INFORMATION: For Applicants’ representations, legal analysis, and 

conditions, please refer to Applicants’ first amended and restated application, dated May 25, 2023, 

which may be obtained via the Commission’s website by searching for the file number at the top of 

this document, or for an Applicant using the Company name search field, on the SEC’s EDGAR 

system. The SEC’s EDGAR system may be searched at 

http://www.sec.gov/edgar/searchedgar/legacy/companysearch.html. You may also call the SEC’s 

Public Reference Room at (202) 551-8090. 

For the Commission, by the Division of Investment Management, under delegated authority. 

Sherry R. Haywood,

Assistant Secretary.