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Gabelli Value 25 Fund

Filed: 28 Apr 10, 8:00pm
April 29, 2010

Ms. Laura E. Hatch
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549

Re:      The Gabelli Value Fund Inc. (the "Fund")
         Post-Effective Amendment No. 26 on Form N-1A
         (Securities Act File No. 33-30139, Investment Company Act File No.
         811-05848)

Dear Ms. Hatch:

         This letter  responds to Staff  comments  communicated  by telephone on
April 7, 2010,  with respect to the  Post-Effective  Amendment  No. 26 ("PEA No.
26") to the Registration  Statement on Form N-1A of the Fund that was filed with
the  Securities  and  Exchange  Commission  (the  "SEC") on  February  26,  2010
(accession number 0000950123-10-017858).

The Fund's  responses to Staff comments are reflected  below.  For comments that
are applicable to both the Class AAA Shares prospectus and the Class ABCI Shares
prospectus,  the comments have only been  addressed  once. The Fund has restated
the substance of the Staff's comments for ease of reference.



         COMMENT  #1-COVER  PAGE:  You  requested  that the Fund  pare  down the
         information  in  the  top  left  hand  corner  to  remove   duplicative
         references.

                  RESPONSE #1: The following parenthetical language that appears
                  at the end of the  disclosure  in the top left hand corner has
                  been  deleted:  "(Net  Asset  Value per share may be  obtained
                  daily by calling 800-GABELLI after 7:00 p.m.)."

         COMMENT  #2-COVER  PAGE:  You requested  that the Fund add the required
         legend disclosure if the Fund intends to utilize a summary prospectus.

                  RESPONSE #2: A summary prospectus will not be utilized at this
                  time and therefore the legend has not been added.

         COMMENT   #3-INFORMATION   ABOUT  THE  FUND'S   INVESTMENT   OBJECTIVE,
         INVESTMENT  STRATEGIES,  AND RELATED RISKS: You requested that the Fund
         remove the last bullet point under: "The actual events that may lead to
         a significant increase in the value of a company's securities include:"
         if the actual event is not applicable.

                  RESPONSE #3: The last bullet  point  discloses an actual event
                  that the Fund believes may lead to a  significant  increase in
                  the value of a company's  securities  and  therefore  the last
                  bullet point has not been removed.

         COMMENT  #4-PERFORMANCE  TABLE:  You requested that the Fund delete the
         second sentence of the second  paragraph of the text regarding  "Return
         After  Taxes on  Distributions  and Sale of Fund  Shares"  if it is not
         applicable.

                  RESPONSE  #4:  If  this  disclosure  is  not  applicable,  the
                  disclosure will be removed.

         COMMENT  #5-STATEMENT OF ADDITIONAL  INFORMATION ("SAI"): You requested
         that the Fund  include the new  corporate  governance  and board member
         disclosure in the SAI.

                  RESPONSE  #5: The new  corporate  governance  and board member
                  disclosure will be included in the SAI.



The Fund hereby  represents  that,  with respect to the filing of the PEA No. 26
made by the Fund with the SEC and reviewed by the Staff, it acknowledges that:

         1.       the Fund is  responsible  for the adequacy and accuracy of the
                  applicable disclosure in the filing;

         2.       Staff  comments or changes to  disclosure in response to Staff
                  comments in the filing  reviewed by the Staff do not foreclose
                  the SEC from taking any action with respect to the filing; and

         3.       the Fund may not  assert  Staff  comments  as a defense in any
                  proceeding  initiated  by  the  SEC or any  person  under  the
                  federal securities law of the United States.

         Should you have any questions  regarding the  foregoing,  please do not
         hesitate  to  contact  Helen  A.  Robichaud  at PNC  Global  Investment
         Servicing, Inc., the Fund's Sub-Administrator, at 617-338-4595.

         Very truly yours,

         /s/ Bruce N. Alpert
         -------------------
         Bruce N. Alpert
         President

         cc:  Helen A. Robichaud                   Arlene Lonergan
              PNC Global Investment                PNC Global Investment
              Servicing, Inc.                      Servicing, Inc.

              Peter D. Goldstein                   Rose DiMartino
              Gabelli Funds, LLC                   Willkie, Farr & Gallagher LLP

              David Joire
              Willkie, Farr & Gallagher LLP