Your are correct in your assumption regarding the criteria for a commodity pool, however the point you may be overlooking here is that 141 is making itself available to trade for private "investmentment clubs" and as such, the private investment club must first be set up as a "Limited Liability Corporation" or "LLC" in order for 141 to trade for them.
In the case of these LLC's, each club can have no more than 15 participants nor exceed the $400.000 threshold for investment capital however there can be multiple clubs if the private clubs fall within the "lLC" designation along with the above conditions.
Hope this helps.
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