EXHIBIT INDEX
Exhibit A: Attachment to item 77o:
Transactions effected pursuant to Rule 10f-3
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Exhibit A:
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Completel Europe N.V.
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
27,200,000
Date of Purchase
3/27/00
Number of shares Purchased
10,000
Date of Public Offer
3/28/00
Fund Price Paid
$17.0890
Public Offering Price
$17.0890
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
5.75%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Salomon Smith Barney, Inc.
Needham Company, Inc Mgr or Co-Mgr?
No
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Diversa Corporation
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
7,250,000
Date of Purchase
2/14/00
Number of shares Purchased
1,000
Date of Public Offer
2/14/00
Fund Price Paid
$24.0000
Public Offering Price
$24.0000
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
7.00%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Bear Stearns Securities Corporation
Needham Company, Inc Mgr or Co-Mgr?
No
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Dobson Communications Corporation
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
25,000,000
Date of Purchase
2/3/00
Number of shares Purchased
1,500
Date of Public Offer
2/4/00
Fund Price Paid
$22.0000
Public Offering Price
$22.0000
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
5.75%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Lehman Brothers
Needham Company, Inc Mgr or Co-Mgr?
No
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Netpliance, Inc.
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
8,000,000
Date of Purchase
3/17/00
Number of shares Purchased
500
Date of Public Offer
3/17/00
Fund Price Paid
$18.0000
Public Offering Price
$18.0000
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
7.00%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Donaldson Lufkin & Jenrette, Inc.
Needham Company, Inc Mgr or Co-Mgr?
No
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Switchboard, Inc.
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
5,500,000
Date of Purchase
3/2/00
Number of shares Purchased
10,000
Date of Public Offer
3/2/00
Fund Price Paid
$15.0000
Public Offering Price
$15.0000
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
7.00%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Robertson Stephens
Needham Company, Inc Mgr or Co-Mgr?
No
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Therma-Wave, Inc.
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
9,000,000
Date of Purchase
2/3/00
Number of shares Purchased
2,500
Date of Public Offer
2/4/00
Fund Price Paid
$20.0000
Public Offering Price
$20.0000
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
7.00%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Lehman Brothers
Needham Company, Inc Mgr or Co-Mgr?
No
NEEDHAM Growth Fund
Rule 10F-3
Issuer
VIA Net.Works, Inc.
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
14,300,000
Date of Purchase
2/11/00
Number of shares Purchased
500
Date of Public Offer
2/11/00
Fund Price Paid
$21.0000
Public Offering Price
$21.0000
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
6.75%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Donaldson, Lufkin & Jenrette, Inc.
Needham Company, Inc Mgr or Co-Mgr?
No
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Viasystems Group, Inc.
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
44,000,000
Date of Purchase
3/23/00
Number of shares Purchased
20,000
Date of Public Offer
3/24/00
Fund Price Paid
$21.0000
Public Offering Price
$21.0000
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
5.50%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Morgan Stanley Dean Witter & Co.
Needham Company, Inc Mgr or Co-Mgr?
No
NEEDHAM Growth Fund
Rule 10F-3
Issuer
GSI Lumonics, Incorporated
Type of Security
Common
IPO or Security
Secondary
SEC Registered
Yes
Total Offering
4,000,000
Date of Purchase
4/12/00
Number of shares Purchased
5,000
Date of Public Offer
4/12/00
Fund Price Paid
$17.00
Public Offering Price
$17.00
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
5.24%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
CIBC Oppenheimer
Needham Company, Inc Mgr or Co-Mgr?
Yes
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Manufacturers Services Ltd.
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
11,000,000
Date of Purchase
6/23/00
Number of shares Purchased
1,000
Date of Public Offer
6/23/00
Fund Price Paid
$16.00
Public Offering Price
$16.00
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
7.00%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Donaldson Lufkin Jenrette
Needham Company, Inc Mgr or Co-Mgr?
No
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Merix Corporation
Type of Security
Common
IPO or Security
Secondary
SEC Registered
Yes
Total Offering
3,000,000
Date of Purchase
5/4/00
Number of shares Purchased
5,000
Date of Public Offer
5/4/00
Fund Price Paid
$19.25
Public Offering Price
$19.25
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
5.50%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Thomas Weisel Partners LLC
Needham Company, Inc Mgr or Co-Mgr?
Yes
NEEDHAM Growth Fund
Rule 10F-3
Issuer
Nova Measuring Instruments Ltd.
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
3,000,000
Date of Purchase
4/11/00
Number of shares Purchased
10,000
Date of Public Offer
4/11/00
Fund Price Paid
$18.00
Public Offering Price
$18.00
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
7.00%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Chase H&Q
Needham Company, Inc Mgr or Co-Mgr?
Yes
NEEDHAM Growth Fund
Rule 10F-3
Issuer
StorageNetworks, Incorporated
Type of Security
Common
IPO or Security
IPO
SEC Registered
Yes
Total Offering
9,000,000
Date of Purchase
6/29/00
Number of shares Purchased
100
Date of Public Offer
6/30/00
Fund Price Paid
$27.00
Public Offering Price
$27.00
Firm Commitment Underwriting ?
Yes
Underwriting gross spread as % of Proceeds
7.00%
Consistent with average industry % of gross spread
Yes
Company operational for 3 years?
Yes
Less than 3% of fund assets used for purchase?
Yes
Fund's purchase represent's less than 4% of the offering?
Yes
Name of underwriter(s) purchased from?
Credit Suisse First Boston
Needham Company, Inc Mgr or Co-Mgr?
No
