[Letterhead of Comstock Funds, Inc.]



January 21, 2009                                                     38573.00001


Ms. Laura E. Hatch
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549

Re:      GAMCO Westwood Funds (the "Trust")
         Registration Statement on Form N-14 (333-156354)

Dear Ms. Hatch:


In connection with your review of the Registration Statement on Form N-14 (the
`Registration Statement") of the Trust that was filed with the Securities and
Exchange Commission (the "SEC") on December 19, 2008 (accession number
0000935069-08-003048), with respect to the GAMCO Westwood Mighty Mites Fund (the
"Fund"), a series of the Trust, the Trust acknowledges that:

         1.       In connection with the comments made by the Staff of the SEC,
                  the Staff has not passed on the accuracy or adequacy of the
                  disclosure made herein, and the Trust and its management are
                  solely responsible for the content of such disclosure;

         2.       The Staff's comments, and changes in disclosure in response to
                  the Staff's comments, do not foreclose the SEC or other
                  regulatory body from the opportunity to seek enforcement or
                  take other action with respect to the disclosure made herein;
                  and

         3.       The Trust represents that neither it nor its management will
                  assert the Staff's comments or changes in disclosure in
                  response to the Staff's comments as a defense in any action or
                  proceeding by the SEC or any person.


If you have any questions, please feel free to contact me at 914-921-5105.


Sincerely,


/s/ Bruce N. Alpert
Bruce N. Alpert, President
GAMCO Westwood Funds