[LETTERHEAD OF PAUL, HASTINGS, JANOFSKY & WALKER LLP]TTED]


(212) 318-6275
November 14, 2008                                                 41472.00003


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 Money Market Funds (the "Company")
         Post-Effective Amendment No. 22 to the Registration Statement
         on Form N-1A (33-48220)

Dear Ms. Hatch:

This letter responds to your additional comments communicated by telephone on
November 14, 2008, with respect to Post-Effective Amendment No. 22 to the
Registration Statement on Form N-1A (the "Registration Statement") of the
Company that was filed with the Securities and Exchange Commission on November
14, 2008 (accession number 0000935069-08-002659), with respect to U.S. Treasury
Money Market Fund (the "Fund"), the only series of the Company.

As we discussed, the Fund would like to include additional disclosure in its
prospectus to provide for a contingent deferred sales charge ("CDSC") with
respect to its Class A Shares. The disclosure with respect to this CDSC is
substantially similar to that of the CDSC applicable to the Class C Shares of
the Fund, which you have already reviewed. As further discussed with you, we
propose to include this additional disclosure in the final prospectus of the
Fund to be filed pursuant to Rule 497(c). For your reference, we have included
the proposed disclosure that will appear in the Fund's prospectus below:

         "Class A Shares of the Fund may only be acquired in exchange for Class
         A Shares of another Gabelli Fund, which typically carry a front-end
         sales load or may be subject to a maximum deferred sales charge
         ("CDSC") if no front-end sales load was paid at the time of purchase
         and such shares were redeemed within 18 months of such purchase. Class
         A Shares of the Fund do not have a front-end sales load, however, the
         Fund's CDSC may apply upon redemption of the Class A Shares of the
         Fund, regardless of the amount of time you held such shares in the
         Fund. The Fund's CDSC will not apply (i) to redemptions of Class A
         Shares of the Fund that had paid the applicable front-end sales load of
         another Gabelli Fund at the time of such purchase, (ii) to redemptions


November 14, 2008
Page 2

         of Class A Shares of the Fund that had been previously invested in
         another Gabelli Fund for the time period required to avoid the payment
         of such Gabelli Fund's CDSC (typically 18 months), or (iii) upon the
         exchange of Class A Shares of the Fund for Class A shares of another
         Gabelli Fund. Following an exchange into another Gabelli Fund, such
         shares will be subject to that Gabelli Fund's CDSC which will be
         calculated by excluding the time such shares were held in the Fund but
         including the time such shares were initially held in the Gabelli Fund
         prior to the exchange into this Fund."

Additionally, we represent that funds in the Gabelli fund complex that permit
exchanges of their Class A shares for Class A shares of the Fund include, or
will include, the following disclosure in their prospectuses with respect to the
imposition of the CDSC:

         "You may also exchange your shares for shares of a money market fund
         managed by the Adviser or its affiliates, without imposition of any
         CDSC at the time of exchange. Upon subsequent redemption from such
         money market fund or the Fund (after re-exchange into the Fund), such
         shares will be subject to the CDSC calculated by excluding the time
         such shares were held in the money market fund."

Should you have any questions regarding the foregoing, please do not hesitate to
contact me at the number listed above. Thank you.

Very truly yours,

/s/ Rachael L. Schwartz

Rachael L. Schwartz
for PAUL, HASTINGS, JANOFSKY & WALKER LLP