Actually, 501 already requires that the indivual investors of the 'club' also be accredited, and the club cannot be formed for the purposes of 'an' investment. However, a group of engineers could form an entity and each become active managers, and their club is able to accept funds from the engineers via a 4(2) exemption under the '33 Act. Then, so long as they didn't run afoul of the '40 Act, they could invest so long as they had $5m in assets. And the neat thing about intellectual property is that the engineers could purchase their stake in the club via a combination of cash and IP, easily and lawfully exceeding the $5m threshold.