[Letterhead of Paul, Hastings, Janofsky & Walker] Atlanta Beijing Brussels Hong Kong London Los Angeles Milan New York Orange County Palo Alto Paris San Diego San Francisco Shanghai Tokyo Washington, DC (212) 318-6275 rachaelschwartz@paulhastings.com January 21, 2009 33428.00001 Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: The GAMCO Westwood Funds (the "Trust") Pre-Effective Amendment No. 1 to the Registration Statement on Form N-14 Registration No. 333-156354 Ladies and Gentlemen: Transmitted herewith for filing is Pre-Effective Amendment No. 1 to the Registration Statement on Form N-14 for the above referenced Trust, on behalf of the GAMCO Westwood Mighty Mites(SM) Fund, a series thereof (the "Mighty Mites Fund"). This Registration Statement is being filed in connection with the proposed reorganization of the B.B. Micro-Cap Growth Fund (the "B.B. Fund"), a series of The B.B. Funds, into the Mighty Mites Fund. Please note that this filing has been marked to show changes from the Trust's Registration Statement on Form N-14 that was filed on December 19, 2008. Pursuant to Rule 461 of the Securities Act of 1933, the Company requests acceleration of the effective date of the Registration Statement to January 21, 2009, or as soon as practicable thereafter. A request for acceleration is transmitted herewith. Please call the undersigned at (212) 318-6275 with any questions or comments you may have regarding the filing. Thank you. Very truly yours, /s/ Rachael L. Schwartz Rachael L. Schwartz for PAUL, HASTINGS, JANOFSKY & WALKER LLP