SECURITIES AND EXCHANGE COMMISSION 

Investment Company Act Release No. 35127; File No. 812-15502 

BIP Ventures Evergreen BDC, et al. 

February 8, 2024 

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

ACTION: Notice. 

Notice of application for an order (“Order”) under sections 17(d) and 57(i) of the Investment 

Company Act of 1940 (the “Act”) and rule 17d-1 under the Act to permit certain joint 

transactions otherwise prohibited by sections 17(d) and 57(a)(4) of the Act and rule 17d-1 under 

the Act. 

Summary of Application: Applicants request an order to permit certain business development 

companies and closed-end management investment companies to co-invest in portfolio 

companies with each other and with certain affiliated investment entities. 

Applicants: BIP Ventures Evergreen BDC, BIP Capital, LLC, BIP Capital Management 

Services, LLC, BIP Capital Mini Fund, LP, BIP Capital Mini Fund II, LP, BIP Capital Mini 

Fund II-QP, LP, BIP Capital Mini Fund III, LP, BIP Capital Mini Fund III-QP, LP, BIP Capital 

Mini Fund IIIb, LP, BIP Capital Mini Fund IIIb-QP, LP, BIP Capital Venture Fund IV, LP, BIP 

Capital Venture Fund IV-QP, LP, Panoramic Annex Fund 4, LP, Panoramic Annex Fund 4-QP, 

LP, Panoramic Venture Fund 5, LP, Panoramic Venture Fund 5-QP, LP, BIP Capital 2080 Media 

Equity VII, LLC, BIP Capital 2080 Media Equity X, LLC, BIP Capital AchieveIt Series E-1, 

LLC, BIP Capital ConnexPay Convertible Note I, LLC, BIP Capital ConnexPay Equity I, LLC, 

BIP Capital Huddle Convertible Note, LLC, BIP Capital Huddle Equity II, LLC, BIP Capital 

PAN Convertible Note, LLC, BIP Capital PAN Equity I, LLC, BIP Capital PAN Equity II, LLC, 
BIP Capital Wellview Senior Debt II, LLC Panoramic Trella Acquisition I, LP, Panoramic Trella 

Acquisition I-QP, LP, Panoramic UserIQ Equity II, LLC, Panoramic Wellview Sentry Merger I, 

LLC, Panoramic Annex Fund 4b, LP, Panoramic Annex Fund 4b-QP, LP, Panoramic Mediafly 

Equity I, LLC, Panoramic ShiftMed Equity I, LLC, Panoramic ShiftMed Equity I-QP, LLC, 

Panoramic Connexpay Equity II-AI, LLC, Panoramic Connexpay Equity II-QP, LLC, BIP 

Capital 2080 Media Investments IV, LLC, BIP Capital 2080 Media Investment V, LLC, BIP 

Capital 2080 Media Investment VI, LLC, BIP AchieveIt Investments, LLC, BIP VoApps Series 

A, LLC, BIP Early Stage Fund I, LP, BIP Early Stage Fund I-QP, LP, BIP Capital AchieveIt 

Series D, LLC, BIP Capital AchieveIt Series E, LLC, BIP Capital Growth Fund III, LP, BIP 

Capital Growth Fund III-QP, LP, BIP Capital Wellview Series A-3, LLC, BIP Capital Huddle I, 

LLC, BIP Capital Huddle I-QP, LLC, BIP Capital EmpowHR Convertible Note I, LLC, BIP 

Capital EmpowHR Convertible Note II, LLC, Panoramic EmpowHR Equity I, LLC, Panoramic 

ShiftMed Equity II-AI, LLC, Panoramic ShiftMed Equity II-QP, LLC, Panoramic 2080 Media 

Equity XI-AI, LLC, Panoramic 2080 Media Equity XI-QP, LLC, and Panoramic Joymo Equity I, 

LLC. 

Filing Dates: The application was filed on August 28, 2023 and amended on October 17, 2023, 

December 1, 2023, December 26, 2023, and February 6, 2024. 

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 

e-mailing 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 March 4, 2024, 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: Todd Knudsen, 

tknudsen@bipventures.vc; Kara Mullins, kmullins@bipventures.vc; Blake E. Estes, 

blake.estes@alston.com. 

FOR FURTHER INFORMATION CONTACT: Laura J. Riegel, Senior Counsel, or Thomas 

Ahmadifar, 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’ fourth amended and restated application, dated February 

6, 2024, 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, at 

https://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.