[LETTERHEAD OF PAUL, HASTINGS, JANOFSKY & WALKER LLP]
Securities and Exchange Commission
100 F Street, N.E.
Washington, DC 20549
Re: | The Gabelli SRI Fund, Inc. (the “Fund”) |
Pre-Effective Amendment No. 2 to the Registration Statement on Form N-1A under the Securities Act of 1933 (Registration No. 333-141093)
In connection with the Securities and Exchange Commission’s (the “Commission”) review of Pre-Effective Amendment No. 2 to the Registration Statement filed on behalf of the Fund on May 31, 2007, the Fund hereby acknowledges that:
| (i.) | The Commission’s declaring the filing effective does not foreclose the Commission from taking any action with respect to the filing; |
| (ii.) | The Fund is fully responsible for the adequacy and accuracy of the disclosure in the filing; and |
| (iii.) | The Fund may not assert the acceleration of the effective date of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States. |
If you have any questions or comments regarding the filing, please contact me at (212) 318-6962.
Very truly yours,
/s/ Matthew J. Van Wormer
Matthew J. Van Wormer
On Behalf of The Gabelli SRI Fund, Inc.