| Phone: | (212)885-5205 |
| Fax: | (917)332-3033 |
| Email: | ajanell@blankrome.com |
October 17, 2014
VIA EDGAR CORRESPONDENCE
Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, D.C. 20549
Attention: Asen Parachkevov
| Re: | Cornerstone Total Return Fund, Inc. | |
| Preliminary Proxy Statement on Schedule 14A | ||
| Notice of Filing |
Dear Mr. Parachkevov:
The above-referenced filing (the “Preliminary Proxy Statement”) of our client, Cornerstone Total Return Fund, Inc. (the “Fund”), filed on October 17, 2014, pursuant to Rule 14a-6 of the Securities Exchange Act of 1934, is furnished in connection with the solicitation of proxies by the Board of Directors of the Fund, a New York corporation for use at a special meeting of stockholders to be held on December 8, 2014, 1075 Hendersonville Road, Suite 250, Asheville, North Carolina, 28803, to approve a proposed one-for-four reverse stock split and the related amendment to the Certificate of Incorporation.
Please contact me at (212) 885-5205 or Thomas R. Westle at (212) 885-5239 with any questions you may have or for any further information you may desire.
| Very truly yours, | |
| /s/ Allison H. Janell | |
| Allison H. Janell |
