Schedule 13G: Turtle Creek Reports 2.79M Shares, 5.7% of CCOI

Rhea-AI Filing Summary

Turtle Creek Asset Management Inc. reports beneficial ownership of 2,792,711 shares of Cogent Communications Holdings, Inc. common stock, representing 5.7% of the class. The filing classifies Turtle Creek as an investment adviser and states the shares are held for the benefit of unit holders of mutual funds it manages. Turtle Creek asserts the shares were acquired and are held in the ordinary course of business, not for the purpose of changing or influencing control of the issuer. Voting and dispositive power over the reported shares are reported as solely held by Turtle Creek.

Positive

• Material disclosure of ownership: Turtle Creek reports a clear 5.7% beneficial stake, improving transparency
• Passive classification: Filing under Schedule 13G and certification indicate shares are held in the ordinary course and not for control
• Sole voting/dispositive power: Turtle Creek reports sole authority over voting and disposition for the reported shares

Negative

• None.

Insights

Financial Analyst

TL;DR: A 5.7% passive stake disclosed by an investment adviser signals a notable, but non-control, ownership position.

Turtle Creek's Schedule 13G reports a meaningful minority stake of 2,792,711 shares (5.7%). As an investment adviser filing under the Schedule 13G framework, the declaration that the position is held in the ordinary course and not for control purposes indicates a passive, regulatory-compliant disclosure rather than an activist intent. The sole voting and dispositive power reported suggests Turtle Creek directly manages disposition decisions for the funds it advises. For investors, this is material as it identifies a substantial institutional holder, but the filing contains no indication of strategic change or governance pressure.

Corporate Governance Expert

TL;DR: Disclosure of >5% ownership is governance-relevant but explicitly non-control; no immediate governance implications stated.

The Schedule 13G confirms Turtle Creek as an investment adviser holding a 5.7% stake and explicitly certifies the position is not intended to influence control. This distinction matters: Schedule 13G is for passive investors and implies limited engagement on board control or corporate actions. The filing notes shares are held for mutual fund unit holders, reducing the likelihood of concentrated investor-driven governance initiatives. The filing does not identify any arrangements, groups, or shared voting arrangements that would change the governance assessment.

SECURITIES AND EXCHANGE COMMISSION
Washington, D.C. 20549

SCHEDULE 13G

UNDER THE SECURITIES EXCHANGE ACT OF 1934

COGENT COMMUNICATIONS HOLDINGS, INC.

(Name of Issuer)

Common Stock

(Title of Class of Securities)

19239V302

(CUSIP Number)

06/30/2025

(Date of Event Which Requires Filing of this Statement)

Check the appropriate box to designate the rule pursuant to which this Schedule is filed:

Rule 13d-1(b)

Rule 13d-1(c)

Rule 13d-1(d)

SCHEDULE 13G

CUSIP No. 19239V302

1

Names of Reporting Persons

Turtle Creek Asset Management Inc.

2

Check the appropriate box if a member of a Group (see instructions)

(a)
(b)

3

Sec Use Only

4

Citizenship or Place of Organization

CANADA (FEDERAL LEVEL)

Number of Shares Beneficially Owned by Each Reporting Person With:

5	Sole Voting Power 2,792,711.00
6	Shared Voting Power 0.00
7	Sole Dispositive Power 2,792,711.00
8	Shared Dispositive Power 0.00

9

Aggregate Amount Beneficially Owned by Each Reporting Person

2,792,711.00

10

Check box if the aggregate amount in row (9) excludes certain shares (See Instructions)

11

Percent of class represented by amount in row (9)

5.7 %

12

Type of Reporting Person (See Instructions)

FI

SCHEDULE 13G

Item 1.
(a)	Name of issuer: COGENT COMMUNICATIONS HOLDINGS, INC.
(b)	Address of issuer's principal executive offices: 2450 N Street N.W., Washington, District of Columbia, 20037
Item 2.
(a)	Name of person filing: This statement on Schedule 13G is being filed by Turtle Creek Asset Management Inc. ("Turtle Creek").
(b)	Address or principal business office or, if none, residence: Scotia Plaza, 40 King Street West, Suite 5100, Toronto, Ontario M5H 3Y2 Canada
(c)	Citizenship: Canada
(d)	Title of class of securities: Common Stock
(e)	CUSIP No.: 19239V302
Item 3.	If this statement is filed pursuant to §§ 240.13d-1(b) or 240.13d-2(b) or (c), check whether the person filing is a:
(a)	Broker or dealer registered under section 15 of the Act (15 U.S.C. 78o);
(b)	Bank as defined in section 3(a)(6) of the Act (15 U.S.C. 78c);
(c)	Insurance company as defined in section 3(a)(19) of the Act (15 U.S.C. 78c);
(d)	Investment company registered under section 8 of the Investment Company Act of 1940 (15 U.S.C. 80a-8);
(e)	An investment adviser in accordance with § 240.13d-1(b)(1)(ii)(E);
(f)	An employee benefit plan or endowment fund in accordance with § 240.13d-1(b)(1)(ii)(F);
(g)	A parent holding company or control person in accordance with § 240.13d-1(b)(1)(ii)(G);
(h)	A savings associations as defined in Section 3(b) of the Federal Deposit Insurance Act (12 U.S.C. 1813);
(i)	A church plan that is excluded from the definition of an investment company under section 3(c)(14) of the Investment Company Act of 1940 (15 U.S.C. 80a-3);
(j)	A non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J). If filing as a non-U.S. institution in accordance with § 240.13d-1(b)(1)(ii)(J), please specify the type of institution:
(k)	Group, in accordance with Rule 240.13d-1(b)(1)(ii)(K).
	Investment advisor
Item 4.	Ownership
(a)	Amount beneficially owned: See the response(s) to Item 9 on the attached cover page.
(b)	Percent of class: See the response(s) to Item 11 on the attached cover page.
(c)	Number of shares as to which the person has:
	(i) Sole power to vote or to direct the vote: See the response(s) to Item 5 on the attached cover page.
	(ii) Shared power to vote or to direct the vote: See the response(s) to Item 6 on the attached cover page.
	(iii) Sole power to dispose or to direct the disposition of: See the response(s) to Item 7 on the attached cover page.
	(iv) Shared power to dispose or to direct the disposition of: See the response(s) to Item 8 on the attached cover page.
Item 5.	Ownership of 5 Percent or Less of a Class.
Item 6.	Ownership of more than 5 Percent on Behalf of Another Person.
	If any other person is known to have the right to receive or the power to direct the receipt of dividends from, or the proceeds from the sale of, such securities, a statement to that effect should be included in response to this item and, if such interest relates to more than 5 percent of the class, such person should be identified. A listing of the shareholders of an investment company registered under the Investment Company Act of 1940 or the beneficiaries of employee benefit plan, pension fund or endowment fund is not required. Turtle Creek holds the shares of Common Stock reported herein for the benefit of unit holders of mutual funds managed by Turtle Creek, none of whom is known to Turtle Creek to have an interest of more than 5 percent of the class.
Item 7.	Identification and Classification of the Subsidiary Which Acquired the Security Being Reported on by the Parent Holding Company or Control Person.
	Not Applicable
Item 8.	Identification and Classification of Members of the Group.
	Not Applicable
Item 9.	Notice of Dissolution of Group.
	Not Applicable

Item 10.

Certifications:

By signing below I certify that, to the best of my knowledge and belief, the securities referred to above were acquired and are held in the ordinary course of business and were not acquired and are not held for the purpose of or with the effect of changing or influencing the control of the issuer of the securities and were not acquired and are not held in connection with or as a participant in any transaction having that purpose or effect, other than activities solely in connection with a nomination under ?? 240.14a-11. By signing below I certify that, to the best of my knowledge and belief, the foreign regulatory scheme applicable to investment fund managers and portfolio managers registered with the Ontario Securities Commission is substantially comparable to the regulatory scheme applicable to the functionally equivalent U.S. institution(s). I also undertake to furnish to the Commission staff, upon request, information that would otherwise be disclosed in a Schedule 13D.

SIGNATURE

After reasonable inquiry and to the best of my knowledge and belief, I certify that the information set forth in this statement is true, complete and correct.

Turtle Creek Asset Management Inc.

Signature:	/s/ Meaghan Einav
Name/Title:	Meaghan Einav, Chief Compliance Officer
Date:	08/14/2025

FAQ

How many Cogent Communications (CCOI) shares does Turtle Creek Asset Management hold?

2,792,711 shares as reported on the Schedule 13G cover page.

What percentage of CCOI does Turtle Creek's holding represent?

5.7% of the outstanding common stock class, per the filing.

Is Turtle Creek filing as an activist investor or seeking control of CCOI?

No. The filing certifies the position is held in the ordinary course of business and not for the purpose of changing or influencing control.

Under what capacity is Turtle Creek filing this Schedule 13G?

As an investment adviser, holding the shares for the benefit of mutual fund unit holders it manages.

Does the filing indicate any shared voting or dispositive power over the reported shares?

No. The filing reports sole voting power and sole dispositive power for the 2,792,711 shares and zero shared powers.