INDEPENDENT VERDICT
HE-0721 Fund I is not a conventional flagship venture fund despite carrying the Zero Prime Ventures name. Its September 14, 2026 Form D shows a highly concentrated, deal-specific structure: the exact $4,999,990 offering was already completely sold, only two investors participated, the first sale occurred September 10, and the stated minimum investment was $10,000. Fund GP, LLC is named as General Partner, while Belltower Fund Group, Ltd. appears only as agent of the GP. The filing also estimates $8,000 payable to the fund administrator and/or affiliates to cover administrative expenses for the life of the fund. Those facts point toward a discrete series vehicle rather than a new diversified Zero Prime flagship. The public Form D does not identify the underlying company or security held by HE-0721, so the $5 million should not be described as Zero Prime's overall fundraising or AUM. SEC records confirm the capital structure; the actual portfolio asset remains undisclosed in the filing.
THE SERIES STRUCTURE IS OLDER THAN HE-0721 — AND ONE PRIOR VEHICLE STILL CARRIES THE OLD BRAND NAME IN ITS SEC HISTORY
Zero Prime Ventures has repeatedly used coded series vehicles. MO-0523 Fund II, a series of Zero Prime Ventures, LP filed in June 2025 with a $1,022,454 offering that was fully sold to three investors, a $10,000 minimum and the same Fund GP / Belltower operating architecture. Another issuer, ON-0731 Fund II, a series of Zero Prime Ventures, LP, filed in December 2024. Even more revealing is MO-0724 Fund I: its SEC record explicitly shows a previous name of "MO-0724 Fund I, a series of Data Community Fund, LP" before appearing as "a series of Zero Prime Ventures, LP." That is unusually strong evidence of the manager's rebrand being carried through at the legal vehicle level rather than existing only in marketing language. The series names therefore preserve a history of the transition from Data Community Fund to Zero Prime Ventures.
THE PUBLIC ZERO PRIME BRAND TELLS A VERY DIFFERENT STORY FROM THE LYNNWOOD ADMINISTRATIVE ADDRESS
Zero Prime's official website presents a San Francisco-focused early-stage VC firm founded in 2023 to back deeply technical engineer-founders building AI infrastructure, platforms and applications. Pete Soderling is identified as GP, and the firm's portfolio includes companies such as Cusp AI, Higgsfield, Hex, Modal, MotherDuck, Runware, DataHub and Hightouch. That investment identity is substantially more specific than the HE-0721 Form D, which contains no AI language and uses a Lynnwood, Washington address associated with Belltower administrative infrastructure. This split is important: the SEC series entity is administered through one legal/operational layer, while the investment brand and portfolio selection sit at another. Belltower should therefore not be described as Zero Prime's investment adviser merely because its address and agent role appear in the filing. The actual venture thesis is established by Zero Prime's own site, which says it invests "Day Zero" in technical founders and focuses on the production AI stack.
ZERO PRIME'S FLAGSHIP HISTORY IS MUCH LARGER THAN HE-0721 AND EXPLAINS WHY THE $5 MILLION NUMBER MUST BE KEPT IN CONTEXT
Zero Prime Ventures II, LP predates these smaller series vehicles and shows a very different scale. Its SEC history traces back to the Data Community Fund II structure, with Peter Soderling and related GP entities named in earlier filings. Public reporting in 2024 said Zero Prime raised a $48 million second fund, above an initial $30 million target and roughly triple the size of its debut fund, with backing reported from firms and networks including Sequoia, Founders Fund, Foundation Capital, Bain Capital Ventures and AngelList. That $48 million flagship figure is separate from HE-0721's $4,999,990 Form D and from later series-SPV amounts. The distinction matters because the firm today appears to operate both a traditional venture-fund platform and smaller coded vehicles for concentrated opportunities. HE-0721's two-investor structure is therefore better viewed as one narrow sleeve within that broader ecosystem than as a measure of Zero Prime's overall institutional scale.
THE PORTFOLIO ALSO SHOWS WHY A CONCENTRATED SERIES VEHICLE COULD CARRY MATERIAL COMPANY-SPECIFIC RISK
Zero Prime's current public portfolio is concentrated in technically demanding AI and data infrastructure categories rather than broad consumer venture exposure. Its official website highlights Cusp AI in materials discovery, Higgsfield in AI video, Hex in collaborative data tools, Modal in serverless AI/data infrastructure, MotherDuck in analytics, Runware in AI-generated imaging, DataHub in enterprise metadata and Hightouch in data activation. Recent 2026 news on the firm's site includes Higgsfield's $400 million Series B, Cusp AI's $450 million Series B and Modal's $87 million Series B. Those events demonstrate that Zero Prime is participating in companies that can move rapidly from seed-stage technical bets to much larger later-stage financing rounds. For HE-0721, that makes the unidentified underlying company especially important: if two investors supplied essentially the entire $5 million vehicle to purchase one startup position, the risk profile would depend far more on that company's valuation, share class, financing round and liquidity path than on diversified portfolio statistics from Zero Prime's flagship funds.
FINAL ASSESSMENT
HE-0721 has at least five facts that make it uniquely identifiable: it sold an exact $4,999,990 to only two investors; it closed within four days of its first sale; it belongs to a recurring coded series structure administered through Fund GP and Belltower; an earlier Zero Prime series filing explicitly preserves the former Data Community Fund name; and the public Zero Prime platform now centers on highly technical AI infrastructure companies while its traditional Fund II was reported at $48 million. The key unresolved issue is asset identity. Without the HE-0721 partnership agreement, subscription documents or portfolio schedule, FilingDossier cannot determine which startup or security the two investors actually funded. That missing fact is more important than generic venture-risk language because it determines whether HE-0721 is a co-investment, secondary purchase, pro-rata follow-on, special allocation or another type of concentrated opportunity.
SEC SNAPSHOT
Issuer: HE-0721 Fund I, a series of Zero Prime Ventures, LP CIK: 0002148882 SEC Form: Form D Accession No.: 0002148882-26-000001 File No.: 021-597306 Film No.: 261375867 Filing Date: September 14, 2026 Year Organized: 2026 Jurisdiction: Delaware Principal Address: 2006 196th St SW, Suite 114, Lynnwood, WA 98036 Telephone: (360) 340-9337 Industry: Pooled Investment Fund Fund Classification: Venture Capital Fund Investment Company Registered: No Investment Company Act Exclusion: Section 3(c)(1) Offering Exemption: Rule 506(b) Security Type: Pooled Investment Fund Interests Offering Amount: $4,999,990 Amount Sold: $4,999,990 Remaining: $0 Investors: 2 Minimum Investment: $10,000 First Sale: September 10, 2026 Offering Duration Over One Year: No Sales Commissions: $0 Finder's Fees: $0 Estimated Item 16 Payment: $8,000 Item 16 Description: One-time fee paid to the fund administrator and/or affiliates to cover administrative expenses for the life of the fund General Partner: Fund GP, LLC Agent of General Partner: Belltower Fund Group, Ltd. Signer: Abraham Wilson Signer Role: Authorized Officer of the Agent of Issuer's GP
ZERO PRIME SERIES HISTORY
MO-0724 Fund I, a series of Zero Prime Ventures, LP: Confirmed Previous SEC Name: MO-0724 Fund I, a series of Data Community Fund, LP ON-0731 Fund II, a series of Zero Prime Ventures, LP: Confirmed MO-0523 Fund II, a series of Zero Prime Ventures, LP: Confirmed MO-0523 Offering Amount: $1,022,454 MO-0523 Amount Sold: $1,022,454 MO-0523 Investors: 3 MO-0523 Minimum Investment: $10,000 HE-0721 Fund I: Confirmed HE-0721 Amount Sold: $4,999,990 HE-0721 Investors: 2 HE-0721 Fully Sold: YES
WEBSITE / ENTITY PENETRATION
Official Zero Prime Ventures website confirmed: YES Public brand name: Zero Prime Ventures Former brand name Data Community Fund independently supported: YES Pete Soderling GP role confirmed by official website: YES Official website says firm founded in 2023: YES Official strategy focused on AI and data infrastructure: YES Official portfolio publicly disclosed: YES Cusp AI relationship publicly disclosed: YES Higgsfield relationship publicly disclosed: YES Hex relationship publicly disclosed: YES Modal relationship publicly disclosed: YES MotherDuck relationship publicly disclosed: YES Runware relationship publicly disclosed: YES DataHub relationship publicly disclosed: YES Hightouch relationship publicly disclosed: YES HE-0721 underlying company publicly identified in Form D: NO Fund GP, LLC GP role confirmed by SEC: YES Belltower Fund Group GP-agent role confirmed by SEC: YES Belltower identified as investment manager by SEC: NO HE-0721 official dedicated website confirmed: NO Separate HE-0721 investment adviser / CRD confirmed: NO Zero Prime Ventures II historical SEC filing confirmed: YES Publicly reported Zero Prime Ventures II size: $48 million HE-0721 $4.99999M amount equal to Zero Prime platform AUM: NO
CORE INVESTOR QUESTIONS
Which portfolio company or security does HE-0721 actually own Why was the offering set at the unusually precise amount of $4,999,990 Who are the two investors that supplied the entire vehicle Is either investor affiliated with Zero Prime, Pete Soderling or another fund Was HE-0721 created for a new primary financing round, secondary purchase or follow-on investment Does the vehicle invest alongside Zero Prime Ventures II Does Zero Prime Ventures II receive allocation priority over series vehicles What share class or security was acquired At what company valuation was the investment made Does HE-0721 hold only one company What carry or performance allocation applies Is there a management fee in addition to the disclosed $8,000 administrative amount What services are included in the $8,000 lifetime administration charge How are liabilities segregated from other Zero Prime Ventures series What economic role does Fund GP, LLC play What exact relationship exists between Fund GP, LLC and Pete Soderling's investment-management platform Why are the series vehicles administered from Lynnwood while the public investment brand is associated with San Francisco How are investment decisions documented between Zero Prime's flagship funds and special series vehicles
PRIMARY EVIDENCE REVIEWED
SEC Form D for HE-0721 Fund I, a series of Zero Prime Ventures, LP filed September 14, 2026. SEC Form D for MO-0523 Fund II, a series of Zero Prime Ventures, LP filed June 24, 2025. SEC Form D for ON-0731 Fund II, a series of Zero Prime Ventures, LP. SEC record showing MO-0724 Fund I previously named as a series of Data Community Fund, LP. Historical SEC Form D filings for Zero Prime Ventures II, LP / Data Community Fund II. Zero Prime Ventures official website. Zero Prime Ventures official portfolio and strategy disclosures. Pete Soderling public biography identifying Zero Prime Ventures and its former Data Community Fund identity. Wall Street Journal reporting on Zero Prime Ventures II's $48 million raise and reported institutional backers. Third-party venture databases used only to cross-check portfolio breadth and historical investment activity.
IMPORTANT FORM D NOTICE
HE-0721's $4,999,990 offering belongs to one coded series vehicle and should not be interpreted as Zero Prime Ventures' total AUM, total fund size or cumulative capital raised. The $48 million figure associated with Zero Prime Ventures II is a separate flagship-fund figure reported publicly. Fund GP, LLC and Belltower Fund Group are identified in the HE-0721 filing as GP and GP agent respectively; Belltower is not identified there as the investment adviser. The SEC Form D confirms an exempt-offering notice but does not approve Zero Prime Ventures, HE-0721, its unidentified portfolio asset or any investment valuation.