August 25, 2022

Mindy Rotter, Esq., CPA

Division of Investment Management

Disclosure Review and Accounting Office

U.S. Securities and Exchange Commission

New York Regional Office

100 Pearl Street, Suite 20-100

New York, NY 10004-2616

RE: Gabelli Funds

Dear Ms. Rotter:

Thank you for your oral comments on July 27, 2022 regarding your Sarbanes-Oxley review of the funds listed on Appendix A. The funds have considered your comments and authorized us to respond on their behalf as set forth below. Your oral comments are summarized to the best of our understanding, followed by the funds’ responses.

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Response:  The line graph for Gabelli Value 25 Fund, Inc. Class A in the annual report dated December 31, 2021 should have reflected the impact of the sales charge.  The registrant will ensure that such sales charges will be reflected in future graphs.

Mindy Rotter, Esq., CPA

August 25, 2022

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Response:  Gabelli Gold Fund, Inc. has certain holdings that are currently each over 5% of total assets.  This is due to appreciation of the securities’ value including the results of merger activity within the gold sector, or due to a reduction of the Fund’s total assets, which result in a position becoming a larger portion of total assets.  The portfolio manager of Gabelli Gold Fund, Inc. understands the diversification rule, and will not buy additional shares of securities with greater than 5% positions.  Independently, the Advisor’s compliance department monitors the Fund’s daily trade activity to ensure no additional shares are purchased in greater than 5% positions.   As a result, the Gabelli Gold Fund, Inc. is not in violation of the diversification rule.

Response:  The Financial Highlights of Gabelli Global Small and Mid Cap Value Trust as of December 31, 2021 should have included a footnote stating “Asset coverage per share is calculated by combining all series of preferred shares.”  The registrant will ensure that such footnote is presented in future Financial Highlights.

Response:  The “Payable to bank” liability in the Gabelli Value 25 Fund, Inc.’s statement of assets and liabilities in the annual report dated December 31, 2021 was a cash overdraft at its custodian bank.

5.

Please describe in correspondence the frequency with which “Receivable from Adviser” in the statement of assets and liabilities is settled.  Include in the discussion whether settlement terms are the same terms as “Payable to Adviser”.  [Examples: Gabelli Focused Growth and Income Fund; Gabelli Global Financial Services Fund; Gabelli Enterprise Mergers and Acquisitions Fund; Gabelli Dividend Growth Fund; Gabelli International Growth Fund, Inc; Gabelli Value 25 Fund Inc.; Gabelli Global Content and Connectivity

Mindy Rotter, Esq., CPA

August 25, 2022

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Fund; Gabelli Global Growth Fund; Gabelli Global Rising Income and Dividend Fund; Gabelli International Small Cap Fund; and Gabelli Global Mini Mites Fund.]

Response:  The amounts labeled “Receivable from Adviser” in the statements of assets and liabilities for the funds are settled on a monthly basis.  These are similar to the settlement terms for the amounts “Payable to Adviser”.

Response:  Item C11 in form N-CEN filed December 13, 2021 for Gabelli U.S. Treasury Money Market Fund should have stated that Intercontinental Exchange, Inc. provided pricing services during the period.  The registrant will ensure that the pricing vendor is presented in future form N-CEN filings.

Response:  The Gabelli Global Financial Services Fund confirms that the correct fund name will be used in future audit opinions.

Response:  Gabelli Focused Growth and Income Fund and Gabelli Global Mini Mites Fund have each been operating as a non-diversified investment company.  Each of the other funds referenced (Gabelli Global Financial Services Fund; Gabelli Enterprise Mergers and Acquisitions Fund; Gabelli Global Rising Income and Dividend Fund; Gabelli International Small Cap Fund; and Gabelli Multimedia Trust Inc.) has been operating as a diversified investment company.  In the event a fund wants to become a non-diversified fund, it will first seek shareholder approval.

9.

Each fund had exposure to derivatives during the respective fiscal year ends.  The management discussion of fund performance (“MDFP”) does not discuss the impact of

Mindy Rotter, Esq., CPA

August 25, 2022

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derivatives on each fund.  If performance was materially affected by the derivative exposure, there should be a discussion of the impact included in the MDFP.  Please explain why there was no discussion of this in the MDFP, or confirm that the derivatives exposure had no material effect on the performance of the fund.  [Examples: Gabelli Global Financial Services Fund; Gabelli Enterprise Mergers and Acquisitions Fund; Gabelli ABC Fund; Gabelli Global Content and Connectivity Fund; GDL Fund; and Gabelli Utility Trust.]

Response:  Each fund that utilized derivatives during its respective fiscal year incurred expenses relating to these derivatives that were not material to fund performance, and as such were not discussed in the Management Discussion of Fund Performance.

Response:  The primary benchmark for Gabelli Focused Growth and Income Fund did not change from its preceding fiscal year.  In both fiscal years the primary benchmark was S&P MidCap 400 Index, which was shown in the “Comparative Results” tables in the annual reports as of September 30, 2020 and September 30, 2021, and was also shown in the Fund’s prospectuses dated January 28, 2020 and January 28, 2021. The fund notes, however, that the MDFPs in the 2020 and 2021 annual reports reference other benchmarks. Going forward, the fund will ensure that the MDFP only references the fund’s primary benchmark.

Response:  Each fund confirms that no reference to “yield” or “dividend” is made when describing distributions that contain a return of capital, in marketing materials, financial statement disclosures, or web site.

Response:  Each fund confirms that it has complied with shareholder notice requirements of section 19a of the Investment Company Act of 1940.

Mindy Rotter, Esq., CPA

August 25, 2022

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Response:  Each fund confirms that there are no amounts to be disclosed separately as “Payable to directors” in the statements of assets of liabilities, to comply with Regulation S-X 6-04.  Each fund confirms that, where applicable, amounts payable to fund officers are disclosed separately in the statements of assets and liabilities as “Payable for payroll expenses” to comply with Regulation S-X 6-04.

Response:  The line item labeled “Interest expense” in each fund’s statement of operations relates to interest charged on overdraft balances at the custodian bank, and where applicable, interest charged under the line of credit, when a borrowing is made from the line of credit.

Response:  Form N-CEN filed January 10, 2022 for Gabelli 787 Fund, Inc. incorrectly responded “Yes” to question B22.  The response to question B22 should have been “No”.

Mindy Rotter, Esq., CPA

August 25, 2022

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Should you have any additional comments or concerns, please do not hesitate to contact me at (914) 921-7774.

Mindy Rotter, Esq., CPA

August 25, 2022

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Mindy Rotter, Esq., CPA

August 25, 2022

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