Commission européenne, DG COMP MERGER REGISTRY, 1049 Bruxelles, BELGIQUE  
Europese Commissie, DG COMP MERGER REGISTRY, 1049 Brussel,   BELGIË  
 
Tel: +32 229- 91111. Fax: +32 229 -64301. E -mail: COMP -MERGER -REGISTRY@ec.europa.eu.  
  EUROPEAN COMMISSION  
Brussels, 9.12.2021  
C(2021)  9385 final  
PUBLIC VERSION 
Insight  
1114 Avenue of the Americas, 36th 
Floor  
10036 New York, NY  
United States of America  
 
Vector Capital  
One Market Street, Steuart Tower, 23rd Floor   
941052 -  San Francisco, CA  
United States of America  
Subject : Case M.10527 -  INSIGHT / VECTOR CAPITAL / IRIS HOLDINGS JV 
Commission decision pursuant to Article 6(1)(b) of Council Regulation 
(EC) No  139/20041 and Article 57 of the Agreement on the European 
Economic Area2  
Dear Sir or Madam,  
1. On 17 November 2021, the European Commission received notification of a proposed 
concentration pursuant to Article 4 of the Merger Regulation by which Insight 
Vent ure Management LLC (“Insight”, USA), wholly -owned by Insight Holdings 
Group, LLC, and Vector CM Holdings (Cayman), L.P. (“Vector Capital”, USA), 
controlled by Vector Capital IV International, L.P., acquire within the meaning of Article s 3(1)(b) and 3(4)  of the Merger Regulation joint control over the whole of a 
newly created joint venture, Iris Holdings JV, in order to combine the activities of Campaign Monitor Limited (“CM Group”, UK), currently under sole control of Insight, and Cheetah Holdings Limited ( “Cheetah”, UK), currently under sole control 
of Vector Capital,  by way o f purchase of shares .
3 
                                                 
1 OJ L 24, 29.1.2004, p. 1 ( the ‘Merger Regulation ’). With effect from 1 December 2009,  the Treaty on 
the Functioning of the European Union ( ‘TFEU ’) has introduced certain changes, such as the 
replacement of ‘Communi ty’ by ‘Union’  and ‘common market ’ by ‘internal market ’. The terminology 
of the TFEU will be used throughout this decision.  
2  OJ L 1, 3.1.1994, p.  3 (the ‘EEA Agreement ’). 
3  Publication in the Official Jou rnal of the European Union No C 472 , 23.11.2021 , p.15. 

2 2. The business activities of the undertakings concerned are:  
− for Insight: global venture capital and private equity firm specialis ed in 
investments in growth equit y, buyout, capital for mergers and acquisitions and 
later stage / middle market / mature recapitalis ation and carve -outs. Insight 
primarily invests in the technology sector, focusing on consumer -facing 
technology, and SaaS -based software infrastructure. 
− for Vector Capital: private equity firm focused on investments in technology and 
technology -enabled businesses . 
− for Iris Holdings JV: JV combing activities of CM Group and Cheetah. CM Group provides email and multichannel marketing platforms and services. Cheetah 
provides personalized marketing, combining cross -channel marketing platform 
operations with data mana gement, analytics and services.  
3. After examination of the notification, the European Commission has concluded that 
the notified operation falls with in the scope of the Merger  Regulation and of 
paragraph 5(a) and (c) of the Commission Notice on a simplified procedure for 
treatment of certain concentrations under Council Regulation (EC) No  139/2004.
4 
4. For the reasons set out in the Notice on a simplified procedure, the European 
Commission has decided not to oppose the notified operation and to declare it compatible with the internal market and with the EEA Agreement. This decision is 
adopted in application of Article 6(1)(b) of the Merger  Regulation  and Article 57 of 
the EEA Agreement . 
For the Commission   (Signed)  
Olivier GUERSENT  
Director -General  
                                                 
4  OJ C 366, 14.12.2013, p. 5.