Sec Form 4 Filing - GULATI CHETAN @ 4Front Ventures Corp. - 2021-03-18

FORM 4 Check this box if no longer subject to Section 16. Form 4 or Form 5 obligations may continue. See Instruction 1(b).

UNITED STATES SECURITIES AND EXCHANGE COMMISSION Washington, D.C. 20549 STATEMENT OF CHANGES IN BENEFICIAL OWNERSHIP Filed pursuant to Section 16(a) of the Securities Exchange Act of 1934, Section 17(a) of the Public Utility Holding Company Act of 1935 or Section 30(h) of the Investment Company Act of 1940

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1. Name and Address of Reporting Person GULATI CHETAN 2. Issuer Name and Ticker or Trading Symbol 4Front Ventures Corp. [ FFNTF] 5. Relationship of Reporting Person(s) to Issuer (Check all applicable) X __ Director _____ 10% Owner _____ Officer (give title below) _____ Other (specify below) (Last) (First) (Middle) C/O 4FRONT VENTURES CORP., 5060 N. 40TH STREET, SUITE 120 3. Date of Earliest Transaction (MM/DD/YY) 03/18/2021 (Street) PHOENIX, AZ85018 4. If Amendment, Date Original Filed (MM/DD/YY) 6. Individual or Joint/Group Filing (Check Applicable Line) __ X __ Form filed by One Reporting Person _____ Form filed by More than One Reporting Person (City) (State) (Zip)

Table I - Non-Derivative Securities Acquired, Disposed of, or Beneficially Owned 1.Title of Security (Instr. 3) 2. Transaction Date (MM/DD/YY) 2A. Deemed Execution Date, if any (MM/DD/YY) 3. Transaction Code (Instr. 8) 4. Securities Acquired (A) or Disposed of (D) (Instr. 3, 4 and 5) 5. Amount of Securities Beneficially Owned Following Reported Transaction(s) (Instr. 3 and 4) 6. Ownership Form: Direct (D) or Indirect (I) (Instr. 4) 7. Nature of Indirect Beneficial Ownership (Instr. 4) Code V Amount (A) or (D) Price Class A Subordinate Voting Shares 04/13/2021 C 6,642,074 A $ 0.46 21,160,445 ( 2 ) I Navy Capital Green Fund, LP ( 1 ) Class A Subordinate Voting Shares 04/13/2021 C 300,000 A $ 0.46 21,460,445 ( 2 ) I Navy Capital Green Fund, LP ( 1 )

Table II - Derivative Securities Acquired, Disposed of, or Beneficially Owned ( e.g. , puts, calls, warrants, options, convertible securities) 1. Title of Derivative Security (Instr. 3) 2. Conversion or Exercise Price of Derivative Security 3. Transaction Date (MM/DD/YY) 3A. Deemed Execution Date, if any (MM/DD/YY) 4. Transaction Code (Instr. 8) 5. Number of Derivative Securities Acquired (A) or Disposed of (D) (Instr. 3, 4, and 5) 6. Date Exercisable and Expiration Date (MM/DD/YY) 7. Title and Amount of Underlying Securities (Instr. 3 and 4) 8. Price of Derivative Security (Instr. 5) 9. Number of Derivative Securities Beneficially Owned Following Reported Transaction(s) (Instr. 4) 10. Ownership Form of Derivative Security: Direct (D) or Indirect (I) (Instr. 4) 11. Nature of Indirect Beneficial Ownership (Instr. 4) Code V (A) (D) Date Exercisable Expiration Date Title Amount or Number of Shares Stock Option ( 1 ) $ 1.3 ( 3 ) 03/18/2021 A 200,000 ( 4 ) 03/18/2026 Class A Subordinate Voting Shares 200,000 $ 0 200,000 ( 5 ) D 3% Unsecured Convertible Note $ 0.46 04/13/2021 C 6,642,074 05/14/2020 05/14/2025 Class A Subordinate Voting Shares 6,642,074 $ 0 0 I Navy Capital Green Fund, LP ( 1 ) 3% Unsecured Convertible Note $ 0.46 04/13/2021 C 300,000 07/07/2020 07/07/2025 Class A Subordinate Voting Shares 300,000 $ 0 0 I Navy Capital Green Fund, LP ( 1 )

Reporting Owners Reporting Owner Name / Address Relationships Director 10% Owner Officer Other GULATI CHETAN C/O 4FRONT VENTURES CORP. 5060 N. 40TH STREET, SUITE 120 PHOENIX, AZ85018 X Signatures /s/ Leigh Ann Clifford, attorney-in-fact for Chetan Gulati 04/22/2021 Signature of Reporting Person Date

Explanation of Responses:

( 1 )The Reporting Person has voting and dipositive control over these shares as he is a Managing Member, Head of Research and sits on the investment committee of Navy Capital Green Management, LLC, the investment advisor to Navy Capital Green Fund, LP and Navy Capital Green Co-Invest Fund, LLC. ( 2 )Includes 217,764 Class A Subordinate Voting Shares ("SVS") held by CGRS Investments LLC, over which the Reporting Person has voting and dipositive control, and 7,077,335 SVS held by Navy Capital Green Co-Invest Fund, LLC, over which the Reporting Person has voting and dipositive control. ( 3 )Converted from Canadian exercise price of C$1.63 using an exchange rate of C$1.2 = US$1.00 ( 4 )The option was granted on March 18, 2021 and vests in three equal installments on September 18, 2021, March 18, 2022 and September 18, 2022. ( 5 )Excludes options exercisable for 600,000 SVS at a price of $0.83 per SVS held by the Reporting Person, and warrants to purchase 1,410,000 SVS at a price of $0.71 per SVS held by Navy Capital Green Fund, LP, over which the Reporting Person has voting and dipositive control.

Reminder: Report on a separate line for each class of securities beneficially owned directly or indirectly.

* If the form is filed by more than one reporting person, see Instruction 4(b)(v).

** Intentional misstatements or omissions of facts constitute Federal Criminal Violations. See 18 U.S.C. 1001 and 15 U.S.C. 78ff(a).

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