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Avodah Capital Group, LLC

Greenwood Village, CO

Locations 1
Owners 3
Private funds 19
Advisory services

From the firm’s Form ADV Item 5G.

Item 5F — Regulatory AUM · Item 5G — Advisory services

At a Glance
Firm type
ERA
Registered
Dec 24, 2024
CRD #
319775
Locations
1
Locations 1
Location Advisors City State
0 GREENWOOD VILLAGE CO
GREENWOOD VILLAGE, CO • 0 advisors
Registered Advisors 0

No advisors on record.

Owners & Control Persons 3
Name Title Ownership Schedule
WINDY RIVER INVESTMENTS MANAGING MEMBER D A
JOHNSON, TODD, MICHAEL MANAGING MEMBER D A
McDowell, Jesse CHIEF COMPLIANCE OFFICER NA A
WINDY RIVER INVESTMENTS
MANAGING MEMBER • Ownership D • Schedule A
JOHNSON, TODD, MICHAEL
MANAGING MEMBER • Ownership D • Schedule A
McDowell, Jesse
CHIEF COMPLIANCE OFFICER • Ownership NA • Schedule A
Private Funds 19
Fund Type Gross assets
3699 S MONACO LLC Private Equity Fund 3336250
43RD AVENUE ACG, LLC Private Equity Fund 1387500
AG ARCADIA LLC Private Equity Fund 13355000
AG PACIFIC AG POOL II LLC Private Equity Fund 4100000
AQUINAS ACG LLC Other: SPECIAL PURPOSE INVESTMENT VEHICLE 1300000
AUGUSTINE ACG LLC Private Equity Fund 10250000
AUGUSTINE ACG POOL II LLC Private Equity Fund 827000
AUGUSTINE AG POOL III LLC Private Equity Fund 3065000
DIETRICH ACG LLC Private Equity Fund 1727500
INDIESOCAL OZ FUND LLC Private Equity Fund 2717549
LEWIS CAPITAL LLC Private Equity Fund 3858000
NEWTON ACG LLC Private Equity Fund 2000000
NEWTON ACG POOL II LLC Private Equity Fund 506000
NEWTON AG POOL III LLC Private Equity Fund 860000
PACIFIC AG ACG POOL I LLC Private Equity Fund 22000000
REEP ACG LLC Private Equity Fund 651000
SPURGEON ACG, LLC Private Equity Fund 1500000
WEST HOLDEN PLACE LLC Private Equity Fund 2205593
WEST HOLDEN PLACE OZ FUND LLC Private Equity Fund 3713000
3699 S MONACO LLC
Private Equity Fund • 3336250
43RD AVENUE ACG, LLC
Private Equity Fund • 1387500
AG ARCADIA LLC
Private Equity Fund • 13355000
AG PACIFIC AG POOL II LLC
Private Equity Fund • 4100000
AQUINAS ACG LLC
Other: SPECIAL PURPOSE INVESTMENT VEHICLE • 1300000
AUGUSTINE ACG LLC
Private Equity Fund • 10250000
AUGUSTINE ACG POOL II LLC
Private Equity Fund • 827000
AUGUSTINE AG POOL III LLC
Private Equity Fund • 3065000
DIETRICH ACG LLC
Private Equity Fund • 1727500
INDIESOCAL OZ FUND LLC
Private Equity Fund • 2717549
LEWIS CAPITAL LLC
Private Equity Fund • 3858000
NEWTON ACG LLC
Private Equity Fund • 2000000
NEWTON ACG POOL II LLC
Private Equity Fund • 506000
NEWTON AG POOL III LLC
Private Equity Fund • 860000
PACIFIC AG ACG POOL I LLC
Private Equity Fund • 22000000
REEP ACG LLC
Private Equity Fund • 651000
SPURGEON ACG, LLC
Private Equity Fund • 1500000
WEST HOLDEN PLACE LLC
Private Equity Fund • 2205593
WEST HOLDEN PLACE OZ FUND LLC
Private Equity Fund • 3713000
Registration
Firm Type
ERA
Status
ACTIVE
Registered
Dec 24, 2024
SEC #
802-131880
CRD #
319775
SEC Region
DRO

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Filed: 2026-02-23 Form Version: 10/2021
1Identifying Information
1F(5) Total number of offices, other than your Principal Office and place of business 0
1I Do you have one or more websites Yes
1M Are you registered with a foreign financial regulatory authority No
1N Are you a public reporting company under Sections 12 or 15(d) of the Securities Exchange Act of 1934 No
1O Did you have $1 billion or more in assets on the last day of your most recent fiscal year No
2SEC Registration / Reporting

Exempt Reporting Adviser (Item 2B)

2B(1) Qualify for the exemption from registration as an adviser solely to one or more venture capital funds No
2B(2) Qualify for the exemption from registration because you act solely as an adviser to private funds and have assets under management in the United States of less than $150 million Yes
2B(3) Act solely as an adviser to private funds but you are no longer eligible to check box 2.B.(2) because you have assets under management in the United States of $150 million or more No
3Form of Organization

Organization Type

Limited Liability Company

Fiscal Year End

DECEMBER

Organized Under Laws Of

CO, United States

6Other Business Activities
6B(1) Are you actively engaged in any other business not listed in Item 6.A. (other than giving investment advice) No
6B(3) Do you sell products or provide services other than investment advice to your advisory clients Yes
7Financial Industry Affiliations

Related persons that are (Item 7A)

7A(1) Broker-dealer, municipal securities dealer, or government securities broker or dealer (registered or unregistered) No
7A(2) Other investment adviser (including financial planners) No
7A(3) Registered municipal advisor No
7A(4) Registered security-based swap dealer No
7A(5) Major security-based swap participant No
7A(6) Commodity pool operator or commodity trading advisor (whether registered or exempt from registration) No
7A(7) Futures commission merchant No
7A(8) Banking or thrift institution No
7A(9) Trust company No
7A(10) Accountant or accounting firm No
7A(11) Lawyer or law firm No
7A(12) Insurance company or agency No
7A(13) Pension consultant No
7A(14) Real estate broker or dealer No
7A(15) Sponsor or syndicator of limited partnerships (or equivalent), excluding pooled investment vehicles No
7A(16) Sponsor, general partner, managing member (or equivalent) of pooled investment vehicles Yes
7B Are you an adviser to any private fund Yes
10Control Persons
10A Does any person not named in Item 1.A. or Schedules A, B, or C, directly or indirectly, control your management or policies No
11Disclosure Information
11 Do any of the events below involve you or any of your supervised persons No
11A(1) Been convicted of or plead guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to any felony No
11A(2) Been charged with any felony No
11B(1) Been convicted of or plead guilty or nolo contendere ("no contest") in a domestic, foreign, or military court to a misdemeanor involving: investments or an investment-related business, or any fraud, false statements, or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these offenses No
11B(2) Been charged with a misdemeanor listed in 11.B(1) No
11C(1) Found you or any advisory affiliate to have made a false statement or omission No
11C(2) Found you or any advisory affiliate to have been involved in a violation of SEC or CFTC regulations or statutes No
11C(3) Found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted No
11C(4) Entered an order against you or any advisory affiliate in connection with investment-related activity No
11C(5) Imposed a civil money penalty on you or any advisory affiliate, or ordered you or any advisory affiliate to cease and desist from any activity No
11D(1) Ever found you or any advisory affiliate to have made a false statement or omission, or been dishonest, unfair, or unethical No
11D(2) Ever found you or any advisory affiliate to have been involved in a violation of investment-related regulations or statutes No
11D(3) Ever found you or any advisory affiliate to have been a cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted No
11D(4) In the past ten years, entered an order against you or any advisory affiliate in connection with an investment-related activity No
11D(5) Ever denied, suspended, or revoked your or any advisory affiliate's registration or license, or otherwise prevented you or any advisory affiliate, by order, from associating with an investment-related business or restricted your or any advisory affiliate's activity No
11E(1) Found you or any advisory affiliate to have made a false statement or omission No
11E(2) Found you or any advisory affiliate to have been involved in a violation of its rules (other than a violation designated as a "minor rule violation" under a plan approved by the SEC) No
11E(3) Found you or any advisory affiliate to have been the cause of an investment-related business having its authorization to do business denied, suspended, revoked, or restricted No
11E(4) Disciplined you or any advisory affiliate by expelling or suspending you or the advisory affiliate from membership, barring or suspending you or the advisory affiliate from association with other members, or otherwise restricting your or the advisory affiliate's activities No
11F Has an authorization to act as an attorney, accountant, or federal contractor granted to you or any advisory affiliate ever been revoked or suspended No
11G Are you or any advisory affiliate now the subject of any regulatory proceeding that could result in a "yes" answer to any part of Item 11.C., 11.D., or 11.E No
11H(1)(a) The past ten years, enjoined you or any advisory affiliate in connection with any investment-related activity No
11H(1)(b) Ever found that you or any advisory affiliate were involved in a violation of investment-related statutes or regulations No
11H(1)(c) Ever dismissed, pursuant to a settlement agreement, an investment-related civil action brought against you or any advisory affiliate by a state or foreign financial regulatory authority No
11H(2) Are you or any advisory affiliate now the subject of any civil proceeding that could result in a "yes" answer to any part of Item 11.H(1) No

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