THE GABELLI INVESTOR FUNDS, INC.
One Corporate Center
Rye, New York 10580
April 30, 2007
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549
Attn: Laura Hatch:
Re: The Gabelli Investor Funds, Inc.
Registration Statement on Form N-1A
Post-Effective Amendment No. 20
(FILE NOS: 33-54016 AND 811-07326)
---------------------------------
Dear Ms. Hatch:
In accordance with Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, The Gabelli Investor Funds, Inc.
hereby requests acceleration of the effective date of the above-captioned
Registration Statement so that it may become effective by 5:00 p.m., New York
City time, on April 30, 2007, or as soon as practical thereafter.
In the foregoing connection, the Fund acknowledges that the
disclosure in the Registration Statement is the responsibility of the Fund. The
Fund acknowledges that staff comments or changes in response to staff comments
in the proposed disclosure in the Registration Statement may not be asserted as
a defense in any proceeding which may be brought by any person with respect to
this matter. The Fund also represents to the Securities and Exchange Commission
(the "Commission") that should the Commission, or the staff acting pursuant to
delegated authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing and the Fund
represents that it will not assert this action as a defense in any proceeding
initiated by the Commission or any person under the federal securities laws of
the United States.
The Fund further acknowledges, that the action of the
Commission or the staff, acting pursuant to delegated authority, in declaring
the filing effective does not relieve the Fund from its full responsibility for
the adequacy and accuracy of the disclosures in the filing.
Sincerely,
The Gabelli Investor Funds, Inc.
By: /S/ BRUCE N. ALPERT
--------------------------------------------
Bruce N. Alpert
President
Securities and Exchange Commission
April 30, 2007
Page 4
GABELLI & COMPANY, INC.
One Corporate Center
Rye, New York 10580-1422
April 30, 2007
Securities and Exchange Commission
100 F Street N.E.
Washington, D.C. 20549
Attn: Laura Hatch
Re: The Gabelli Investor Funds, Inc.
Registration Statement on Form N-1A
Post-Effective Amendment No. 20
(FILE NOS.: 33-54016 AND 811-07326)
----------------------------------
Dear Ms. Hatch:
In accordance with Rule 461 of the General Rules and
Regulations under the Securities Act of 1933, the undersigned, in connection
with the offering of common shares of beneficial interest in the above fund and
in its capacity as the principal underwriter of such fund, hereby joins in its
request for acceleration of the effective date of the above-captioned
Registration Statement so that it may become effective by 5:00 p.m., New York
City time, on April 30, 2007 or as soon as practical thereafter.
Sincerely,
Gabelli & Company, Inc.
By: /S/ BRUCE N. ALPERT
-------------------------------------
Bruce N. Alpert
Vice President