Gabelli Funds One Corporate Center Rye, New York 10580 January 21, 2009 Ms. Laura Hatch Securities and Exchange Commission 100 F Street, N.E. Washington, DC 20549 Re: GAMCO Westwood Funds (the "Trust") Pre-Effective Amendment No. 1 to the Registration Statement on Form N-14 (the "Registration Statement") File No. 333-156354 Dear Ms. Hatch: Pursuant to Rule 461 under the Securities Act of 1933, the Trust, on behalf of its series, GAMCO Westwood Mighty Mites Fund, and its undersigned distributor, hereby request acceleration of the effective date of the Registration Statement to January 21, 2009, or as soon thereafter as practicable. All brokers will receive copies of the final prospectus and will have an opportunity to review it before offering the securities to their clients. Very truly yours, GAMCO Westwood Funds on behalf of GAMCO Westwood Mighty Mites(SM) Fund By: /S/ AGNES MULLADY Name: Agnes Mullady Title: Treasurer and Gabelli & Company, Inc. By: /S/ BRUCE N. ALPERT Name: Bruce N. Alpert Title: Vice President