Strategic Capital, a Tokyo-based activist investment firm, has escalated its campaign against GungHo Online Entertainment (TSE: 3765), telling regulators it plans to demand a change at the top of the company if GungHo stays on the Tokyo Stock Exchange rather than delisting through a takeover.
In an amendment to its large shareholding report filed August 27, 2026, with Japan's Kanto Local Finance Bureau, covering a reporting obligation that arose August 20, 2026, Strategic Capital said it will propose in August 2026 that the board choose between removing GungHo's representative director or having the company's chairman step down, if the company remains listed rather than delisting via a third-party acquisition. The fund frames it as an either/or demand: it wants one of the two out, not necessarily both.
The stake itself is little changed: the filing shows the same 13.67% holding ratio reported previously. Strategic Capital holds 7,267,500 GungHo shares, equal to 13.67% of GungHo's 53,161,416 shares outstanding.
| Metric | Value |
|---|---|
| Shares held | 7,267,500 |
| Stake in GungHo | 13.67% |
| GungHo shares outstanding | 53,161,416 |
| Strategic Capital's own funds used | ¥275,000 |
| Client-managed funds used | ¥20.84bn |
What changed in this filing, No. 10 in a series of amendments, is the stated purpose behind the stake. Alongside "pure investment," Strategic Capital now spells out that it is pursuing constructive dialogue and formal proposal rights toward specific ends. The filing lists proposals covering a shift in GungHo's capital structure toward more interest-bearing debt and less reliance on shareholder equity, delisting via acquisition by a third party, a higher dividend, and a buyback targeting shares held by a specific investor and any entities the fund judges that investor to control. The leadership demand applies specifically to the scenario where GungHo remains listed rather than delisting through that acquisition.
The filing also shows how thinly capitalized Strategic Capital's own position is. Of the roughly ¥20.84bn used to build the stake, the fund's own money accounted for just ¥275,000; the rest came from client assets it manages under a discretionary investment contract with Intertrust Trustees (Cayman) Limited. Part of the position carries its own leverage: 800,000 shares are pledged as collateral with Tachibana Securities, and another 500,000 shares are on loan to the same broker under a securities lending agreement.
The report lists Strategic Capital as the sole submitter, with no joint holders attached.
What the filing does not show is whether GungHo's board has responded to any of these proposals, or whether a third-party buyer is actually in the wings. This is Strategic Capital's stated intent under Japan's large shareholding disclosure rules, not confirmation that GungHo has agreed to negotiate, delist, or remove anyone from its leadership.