The Baupost Group, L.L.C.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.A. or 11.B. of Form
ADV.
Criminal
Check item(s) being responded to:
11.A(1)
11.A(2)
11.B(1)
11.B(2)
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
Multiple counts of the same charge arising out of the same event(s) should be reported on the same DRP. Unrelated criminal actions, including separate cases arising
out of the same event, must be reported on separate DRPs. Use this DRP to report all charges arising out of the same event. One event may result in more than one
affirmative answer to the items listed above.
PART I
A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
1059137
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
BLUMENTHAL, THOMAS, WILLIAM
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's
favor.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  If charge(s) were brought against an organization over which you or an advisory affiliate exercise(d) control: Enter organization name, whether or not the
organization was an investment-related business and your or the advisory affiliate's position, title, or relationship. 
2.
Formal Charge(s) were brought in: (include name of Federal, Military, State or Foreign Court, Location of Court - City or County and State or Country, Docket/Case
number). 
PARIS COURT OF FIRST INSTANCE, CRIMINAL COURT, PARIS, FRANCE. DOCKET NUMBER 1114592041.
3.
Event Disclosure Detail (Use this for both organizational and individual charges.)
A. Date First Charged (MM/DD/YYYY): 
01/11/2017
 Exact
 Explanation

If not exact, provide explanation:
THE DATE OF THE CHARGE WAS JANUARY 10, 2017. MR. BLUMENTHAL WAS NOTIFIED OF THE CHARGE ON JANUARY 11, 2017.
B.
Event Disclosure Detail (include Charge(s)/Charge Description(s), and for each charge provide: (1) number of counts, (2) felony or misdemeanor, (3) plea for
each charge, and (4) product type if charge is investment-related). 
MR. BLUMENTHAL WAS CHARGED WITH ONE COUNT OF CRIMINAL TAX FRAUD, A FELONY, UNDER ARTICLES 1741, 1742 AND 1750 OF THE GENERAL TAX CODE
IN FRANCE. MR. BLUMENTHAL PLEAD NOT GUILTY.
C.
Did any of the Charge(s) within the Event involve a felony? 
 Yes
 No
D.
Current status of the Event? 
 Pending
 On Appeal
 Final
E.
Event Status Date (complete unless status is Pending) (MM/DD/YYYY): 
06/20/2018
 Exact
 Explanation
If not exact, provide explanation:
4.
Disposition Disclosure Detail: 
Include for each charge (a) Disposition Type (e.g., convicted, acquitted, dismissed, pretrial, etc.), (b) Date, (c) Sentence/Penalty, (d) Duration (if sentence -
suspension, probation, etc.), (e) Start Date of Penalty, (f) Penalty/Fine Amount, and (g) Date Paid. 
ON JUNE 20, 2018, THE TRIAL COURT CONVICTED MR. BLUMENTHAL, ALONG WITH THE OTHER DIRECTORS OF THE TWO LUXEMBOURG ENTITIES, OF CRIMINAL TAX
FRAUD AND SENTENCED EACH DIRECTOR TO A FINE AND A SUSPENDED SENTENCE. AS TO MR. BLUMENTHAL, THE ORDER OF CONVICTION IMPOSED A FINE OF
APPROXIMATELY US$43,000, TOGETHER WITH A SUSPENDED SENTENCE OF FOUR YEARS. THE DIRECTORS OF THE LUXEMBOURG ENTITIES, INCLUDING MR.
BLUMENTHAL, WERE ALSO DETERMINED TO BE JOINTLY AND SEVERALLY LIABLE AS A CIVIL MATTER FOR THE BALANCE OF THE INCOME TAXES AND RELATED
INTEREST AND PENALTIES DETERMINED TO BE DUE IN RESPECT OF THE LUXEMBOURG ENTITIES. THE BAUPOST PARTNERSHIPS THAT OWNED THESE INVESTMENTS
PAID THEIR PORTION OF THE TAXES, INTEREST AND PENALTIES IN 2017; THE BALANCE WAS SUBSEQUENTLY SATISFIED.
5.
Provide a brief summary of circumstances leading to the charge(s) as well as the disposition. Include the relevant dates when the conduct which was the subject
of the charge(s) occurred. (Your response must fit within the space provided.) 
BETWEEN 2003 AND 2005, PRIVATE FUNDS MANAGED BY BAUPOST MADE THREE FRENCH REAL PROPERTY INVESTMENTS ALONGSIDE THIRD PARTIES THROUGH
LUXEMBOURG COMPANIES (THE "LUXEMBOURG ENTITIES"). THOMAS BLUMENTHAL, A PARTNER, WAS APPOINTED AS A DIRECTOR OF THE LUXEMBOURG ENTITIES.
SUBSEQUENT TO THE 2006 SALE OF THESE INVESTMENTS, THE FRENCH TAX ADMINISTRATION ("FTA") OPENED TAX AUDITS OF THE LUXEMBOURG ENTITIES. THE FTA
ALLEGED THAT THE LUXEMBOURG ENTITIES WERE NOT ELIGIBLE FOR BENEFICIAL TAX TREATMENT UNDER THE FRANCE-LUXEMBOURG TAX TREATY, AND THUS WERE
REQUIRED TO PAY INCOME TAX IN FRANCE. ONE OF THE THREE LUXEMBOURG ENTITIES SUCCESSFULLY PROVED IN FRENCH COURT THAT NO TAX WAS DUE. THE
REMAINING TWO LUXEMBOURG ENTITIES APPEALED THE FTA'S ASSESSMENT TO THE FRENCH SUPREME TAX COURT. ON MARCH 31, 2017, THE FRENCH SUPREME TAX
COURT RULED AGAINST THESE LUXEMBOURG ENTITIES. IN 2011, THE FTA REFERRED FOR INVESTIGATION POTENTIAL CHARGES AGAINST ALL OF THE DIRECTORS OF
THE TWO REMAINING LUXEMBOURG ENTITIES, INCLUDING MR. BLUMENTHAL, ALLEGING THAT THESE LUXEMBOURG ENTITIES AND THEIR DIRECTORS HAD ENGAGED
IN TAX FRAUD AS A RESULT OF THE FAILURE BY THESE LUXEMBOURG ENTITIES TO PAY INCOME TAX IN FRANCE. ON JANUARY 11, 2017, MR. BLUMENTHAL WAS
NOTIFIED THAT A MAGISTRATE JUDGE HAD CHARGED THE DIRECTORS OF THESE TWO LUXEMBOURG ENTITIES, INCLUDING MR. BLUMENTHAL, WITH COMMITTING
CRIMINAL TAX FRAUD. FOLLOWING A TRIAL, THE COURT ON JUNE 20, 2018 CONVICTED THE DIRECTORS OF THE TWO LUXEMBOURG ENTITIES, INCLUDING MR.
BLUMENTHAL, OF CRIMINAL TAX FRAUD AND SENTENCED EACH DIRECTOR TO A FINE AND A SUSPENDED SENTENCE. AS TO MR. BLUMENTHAL, THE ORDER OF
CONVICTION IMPOSED A FINE OF APPROXIMATELY US$43,000, TOGETHER WITH A SUSPENDED SENTENCE OF FOUR YEARS. THE DIRECTORS OF THE LUXEMBOURG
ENTITIES, INCLUDING MR. BLUMENTHAL, WERE ALSO DETERMINED TO BE JOINTLY AND SEVERALLY LIABLE AS A CIVIL MATTER FOR THE BALANCE OF THE INCOME
TAXES AND RELATED INTEREST AND PENALTIES DETERMINED TO BE DUE IN RESPECT OF THE LUXEMBOURG ENTITIES. THE BAUPOST PARTNERSHIPS THAT OWNED
THESE INVESTMENTS PAID THEIR PORTION OF THE TAXES, INTEREST AND PENALTIES IN 2017; THE BALANCE WAS SUBSEQUENTLY SATISFIED. MR. BLUMENTHAL
ACTED IN GOOD FAITH FOR THE BENEFIT OF THE BAUPOST PARTNERSHIPS, HAVING FOLLOWED ADVICE FROM PROMINENT INTERNATIONAL TAX ADVISORS IN
CONNECTION WITH THESE INVESTMENTS, AND MR. BLUMENTHAL APPEALED THE JUDGMENT IN 2018. WHILE BAUPOST HAS ALWAYS STRONGLY DISAGREED WITH
THIS VERDICT AND VIEWS THE CONVICTION AS UNWARRANTED, MR. BLUMENTHAL WITHDREW THE APPEAL IN JUNE 2021 WITH THE FULL SUPPORT OF BAUPOST.
THE BAUPOST PARTNERSHIPS DID NOT BEAR ANY PORTION OF THE APPELLATE DEFENSE COSTS OR THE ADDITIONAL TAX OBLIGATION AND WILL NOT BEAR ANY
PORTION OF THE FINE. THE VERDICT DOES NOT IMPACT MR. BLUMENTHAL'S CONTINUING ROLE AS A PARTNER AT BAUPOST.

Includes form instructions and options. Options shown in this text do not identify which boxes were selected.

GENERAL INSTRUCTIONS
This Disclosure Reporting Page (DRP ADV) is an 
INITIAL OR
AMENDED response used to report details for affirmative responses to Items 11.C., 11.D., 11.E., 11.F.
or 11.G. of Form ADV.
Regulatory Action
Check item(s) being responded to:
11.C(1)
11.C(2)
11.C(3)
11.C(4)
11.C(5)
11.D(1)
11.D(2)
11.D(3)
11.D(4)
11.D(5)
11.E(1)
11.E(2)
11.E(3)
11.E(4)
11.F.
11.G.
Use a separate DRP for each event or proceeding . The same event or proceeding may be reported for more than one person or entity using one DRP. File with a
completed Execution Page. 
One event may result in more than one affirmative answer to Items 11.C., 11.D., 11.E., 11.F. or 11.G. Use only one DRP to report details related to the same event. If an
event gives rise to actions by more than one regulator, provide details for each action on a separate DRP.
PART I

A.  The person(s) or entity(ies) for whom this DRP is being filed is (are):
You (the advisory firm)
You and one or more of your advisory affiliates
One or more of your advisory affiliates
If this DRP is being filed for an advisory affiliate, give the full name of the advisory affiliate below (for individuals, Last name, First name, Middle name). 
If the advisory affiliate has a CRD number, provide that number. If not, indicate "non-registered" by checking the appropriate box.
ADV DRP - ADVISORY AFFILIATE
CRD
Number:
866149
This advisory affiliate is 
a Firm
an Individual
Registered:
Yes
No
Name:
KLARMAN, SETH, ANDREW
(For individuals, Last, First,
Middle)
This DRP should be removed from the ADV record because the advisory affiliate(s) is no longer associated with the adviser.
This DRP should be removed from the ADV record because: (1) the event or proceeding occurred more than ten years ago or (2) the adviser is registered or
applying for registration with the SEC or reporting as an exempt reporting adviser with the SEC and the event was resolved in the adviser's or advisory affiliate's
favor.
If you are registered or registering with a state securities authority , you may remove a DRP for an event you reported only in response to Item 11.D(4), and only
if that event occurred more than ten years ago. If you are registered or registering with the SEC, you may remove a DRP for any event listed in Item 11 that
occurred more than ten years ago.
This DRP should be removed from the ADV record because it was filed in error, such as due to a clerical or data-entry mistake. Explain the circumstances: 
B.
If the advisory affiliate is registered through the IARD system or CRD system, has the advisory affiliate submitted a DRP (with Form ADV, BD or U-4) to the IARD or
CRD for the event? If the answer is "Yes," no other information on this DRP must be provided.
 Yes
 No
NOTE: The completion of this form does not relieve the advisory affiliate of its obligation to update its IARD or CRD records.
PART II
1.  Regulatory Action initiated by:
SEC   
Other Federal   
State   
SRO
Foreign
(Full name of regulator, foreign financial regulatory authority, federal, state, or SRO) 
HELLENIC CAPITAL MARKETS COMMISSION
2.
Principal Sanction:
Civil and Administrative Penalt(ies) /Fine(s)
Other Sanctions: 
3.
Date Initiated (MM/DD/YYYY): 
09/13/2017
 Exact
 Explanation
If not exact, provide explanation:
4.
Docket/Case Number:
DECISION: 7/768/27.10.2016 (BAUPOST); 8/768/27.10.2016 (SETH KLARMAN)
5.
Advisory Affiliate Employing Firm when activity occurred which led to the regulatory action (if applicable):
6.
Principal Product Type:
Other
Other Product Types: 
WARRANT
7.
Describe the allegations related to this regulatory action (your response must fit within the space provided):
PURSUANT TO APPLICABLE GREEK LAW, THE REGISTRANT WAS REQUIRED TO REPORT AN INCREASE IN ITS OWNERSHIP OF A LISTED WARRANT TO BOTH THE
HELLENIC CAPITAL MARKET COMMISSION (HCMC) AND THE ISSUER OF THE SECURITY FOLLOWING TRADING IN OCTOBER 2013. THE ISSUER OF THE SECURITY WAS
REQUIRED TO MAKE THE REPORT PUBLIC FOLLOWING RECEIPT. THE REGISTRANT CAUSED THE REQUIRED NOTIFICATION TO BE SUBMITTED TO THE HCMC AND THE
ISSUER WITHIN THE STATUTORY NOTIFICATION PERIOD. THE ISSUER OF THE WARRANTS CLAIMS THAT IT DID NOT TIMELY RECEIVE THE ORIGINAL REPORT AND
ULTIMATELY WAS FOUR DAYS LATE IN MAKING THE REPORT PUBLIC. THE BOARD OF DIRECTORS OF THE HCMC IMPOSED AN ADMINISTRATIVE FINE OF 3,000 EUROS
IN THE AGGREGATE ON THE REGISTRANT AND ITS ADVISORY AFFILIATE, SETH KLARMAN, FOR THE LATE FILING. THE REGISTRANT AND MR. KLARMAN DISAGREE WITH

THE HCMC DECISION.
8.
Current Status?      
 Pending
 On Appeal
 Final
9.
If on appeal, regulatory action appealed to (SEC, SRO, Federal or State Court) and Date Appeal Filed:
If Final or On Appeal, complete all items below. For Pending Actions, complete Item 13 only.
10. How was matter resolved:
Decision
11. Resolution Date (MM/DD/YYYY):
09/13/2017
 Exact
 Explanation
If not exact, provide explanation:
12. Resolution Detail:
A.  Were any of the following Sanctions Ordered (check all appropriate items)?
 Monetary/Fine Amount: $ 3,000.00
 Revocation/Expulsion/Denial
 Disgorgement/Restitution
 Censure
 Cease and Desist/Injunction
 Bar
 Suspension
B.
Other Sanctions Ordered:
Sanction detail: if suspended, enjoined or barred, provide duration including start date and capacities affected (General Securities Principal, Financial
Operations Principal, etc.). If requalification by exam/retraining was a condition of the sanction, provide length of time given to requalify/retrain, type of
exam required and whether condition has been satisfied. If disposition resulted in a fine, penalty, restitution, disgorgement or monetary compensation,
provide total amount, portion levied against you or an advisory affiliate, date paid and if any portion of penalty was waived: 
A 1,000 EURO FINE WAS IMPOSED ON THE REGISTRANT AND A 2,000 EURO FINE WAS IMPOSED ON ITS ADVISORY AFFILIATE, SETH KLARMAN.
13. Provide a brief summary of details related to the action status and (or) disposition and include relevant terms, conditions and dates (your response must fit within
the space provided).
THE BOARD OF DIRECTORS OF HCMC DETERMINED TO IMPOSE AN ADMINISTRATIVE SANCTION FOR THE REPORTING BREACH, DESCRIBED ABOVE IN ITEM 7, ON
BOTH THE REGISTRANT AND ITS ADVISORY AFFILIATE, SETH KLARMAN. THE MONETARY SANCTIONS HAVE BEEN DESCRIBED ABOVE IN ITEM 12 AND NO ADDITIONAL
PROCEEDINGS ARE ANTICIPATED AT THIS TIME.