Ethics
Conflict of Interest & Transparency
Vik’s Newsletter is written independently by Vikram Sekar and is a part of SemiExponent LLC. The ideas and analysis here come from over a dozen years in the semiconductor and technology ecosystem. That experience is an asset, and it shapes what I notice, how I interpret events, and the networks I’m part of.
I write about companies, technologies, and people I’ve interacted with directly or indirectly. Where those relationships matter, I’ll disclose them.
What I Disclose
Financial interests: Any equity holdings, advisory roles, or compensation tied to topics I write about. Disclosures will appear at the top of the relevant post.
Professional relationships: Past or present working relationships that could shape how I see things.
Sponsorships: This newsletter is currently independent. If that changes, sponsorships or partnerships will be clearly labeled.
Consulting & Advisory Work
I take on consulting and advisory engagements as a regular part of my business through SemiExponent LLC. Clients fall into two broad categories: companies (semiconductor firms, technology companies, and their suppliers) and investors (hedge funds, family offices, asset managers, and individual investors).
These engagements can create potential conflicts. Here is how I handle them.
Across all engagements:
I do not seek out or accept material non-public information (MNPI) from any source, and I do not share MNPI with any client or in this newsletter.
All engagements are governed by a written engagement letter. Clients may also require their own compliance attestations, which I am willing to sign where appropriate.
I cannot guarantee that every potential conflict is visible to me in advance. When I become aware of one, I will either decline the engagement or disclose the relationship.
For corporate clients:
If I am advising a company, I will not accept engagements that ask me to evaluate that same company as an investment.
If I am writing about a company that is also a client, I will disclose that relationship at the top of the post.
After ending an advisory relationship with a company, I maintain a reasonable cooling-off period before accepting engagements that involve evaluating that same company.
For investor clients:
I do not share questions, positions, theses, or any other context between clients. Each engagement is treated as confidential.
If a question from one client overlaps with work I am doing for another, I will say so in general terms without revealing identity or specifics, and decline if the conflict is material.
My personal trading is independent of consulting engagements. The substance or direction of questions raised by investor clients does not inform my own trading.
Newsletter coverage and investor clients:
Newsletter coverage is independent of consulting work. I do not change what I write about, what I conclude, or when I publish based on whether a topic is also being researched for an investor client.
Investor client relationships are confidential. I do not disclose them in posts, even when newsletter topics overlap with client work.
Investor clients receive the newsletter on the same schedule as every other paid subscriber. They do not get advance access to posts, drafts, or unpublished views.
Stock Holdings
I hold positions in semiconductor and technology companies, including some I write about. Positions may be long or short, and I may buy, sell, or hold at any time without advance notice.
When I hold a position in a company I am actively writing about, I disclose it at the top of the relevant post.
Holding a position does not prevent me from writing about a company. My views in this newsletter reflect my analysis, not the direction of my trades.
I am under no obligation to disclose individual trades, position sizes, or the full composition of my portfolio.
Podcast
I co-host the SemiDoped podcast. SemiDoped operates as its own entity (SemiDoped LLC), separate from SemiExponent LLC, and maintains its own editorial policies. However, my personal commitments on MNPI and consulting client confidentiality apply wherever I speak publicly, including on the podcast.
What I Won’t Do
I won’t share proprietary or non-public information from current or prior roles.
I won’t present my views as representative of any employer, past or present.
I will not accept compensation in exchange for specific newsletter content, conclusions, or sentiment about any company or security. Sponsorships, when they exist, will be labeled as such and will not influence editorial coverage.
What Disclosure Does (and Doesn’t Do)
Disclosure is necessary, but it doesn’t remove bias. This newsletter is not written from a neutral position. My background shapes what I notice, what I think matters, and what I might overlook.
Writing in public also creates its own incentives: relationships, access, future opportunities. I try to be aware of this, even when it’s not visible in any single post.
There may also be areas I choose not to write about due to prior involvement, access, or judgment calls around confidentiality. If I’m not covering something, that doesn’t mean I don’t have a view on it.
Not Investment Advice
The content published on Vik’s Newsletter, including all newsletter posts and related materials, is for informational and educational purposes only. Nothing in this newsletter constitutes investment advice, financial advice, tax advice, or a recommendation to buy, sell, or hold any security.
I am not a registered investment adviser, broker-dealer, or financial planner. The views expressed here reflect my personal analysis and opinions, which may change without notice.
You should not rely on any information in this newsletter as the basis for an investment decision. Always do your own research and consult a qualified financial professional before making any investment.
Past performance of any security or strategy discussed here is not indicative of future results. Investing involves risk, including the possible loss of principal.
By reading this newsletter, you acknowledge that any investment decisions you make are your own responsibility.
Limitation of Liability
SemiExponent LLC, its owner, affiliates, and any contributors shall not be held liable for any direct, indirect, incidental, consequential, or punitive damages arising from the use of, reliance on, or inability to use any content published in this newsletter or related materials. This includes, but is not limited to, financial losses resulting from investment decisions, trading activity, or any other actions taken based on the content provided.
All content is provided “as is” without warranty of any kind, either express or implied, including but not limited to accuracy, completeness, timeliness, or fitness for a particular purpose.
Governing Law
This statement and any disputes arising from the use of this newsletter shall be governed by and construed in accordance with the laws of the State of Wyoming, without regard to its conflict of law provisions.
This page was last updated on May 5th, 2026.