The information presented in this commentary is not intended as personalized investment advice and does not constitute a
recommendation to buy or sell a particular security or other investments.

This message is not an offer of the Needham Growth Fund, the Needham Aggressive Growth Fund or the Needham Small
Cap Growth Fund. Shares are sold only through the currently effective prospectus. Please read the prospectus or summary
prospectus and consider the investment objectives, risks and charges and expenses of the Funds carefully before you
invest. The prospectus and summary prospectus contain this and other information about the Funds and can be obtained
on our website, www.needhamfunds.com.

Investment returns and principal value will fluctuate, and when redeemed, shares may be worth more or less than their
original cost. Performance data quoted represents past performance, and does not guarantee future results. Current
performance may be higher or lower than these results. Performance current to the most recent month-end may be
obtained by calling our transfer agent at 1-800-625-7071. Total return figures include reinvestment of all dividends and
capital gains.

All three of the Needham Funds have substantial exposure to small and micro capitalized companies. Funds holding
smaller capitalized companies are subject to greater price fluctuation than those of larger companies.
Needham & Company, LLC, member FINRA/SIPC, is the distributor of The Needham Funds, Inc.

The source of the data for each of the Russell 2000 Index and the Russell 3000 Index (together, the “Indexes”) is the
London Stock Exchange Group plc and its group undertakings (collectively, the “LSE Group”). © LSE Group 2019. All
rights in the Indexes vest in the relevant LSE Group company which owns the Index. The Indexes are calculated by or on
behalf of FTSE International Limited or its affiliate, agent or partner. Neither the LSE Group nor its licensors accept any
liability for any errors or omissions in the Indexes; no party may rely on the Index returns shown; and the LSE Group
makes no claim, prediction, warranty or representation about the Fund or the suitability of the Indexes with respect to the
Fund. No further distribution of data from the LSE Group is permitted without the relevant LSE Group company’s
express written consent. The LSE Group is not connected to the Fund and does not promote, sponsor or endorse the Fund
or the content of this prospectus.

Portfolio holdings are subject to change. The Needham Aggressive Growth Fund’s ownership as a percentage of net assets
in the stated securities as of 6/30/19: AMBR: 0.00%; ASPN: 1.91%; BASF: 0.00%; PDFS: 10.53%; TSM: 0.60%;
ENTG: 9.84%; VSM: 0.00%; MRK: 0.00%; AAPL: 8.69%; GVP: 5.76%; MKSI: 3.93%; MFIN: -0.70%; UBNT:
-0.87%; WAB: 1.10%; DRT: 3.90%; VICR: 4.33%; EFII: 0.36%; ENTG: 9.84%; FORM: 1.03%; SMCI: 2.76%.