CALAMOS ASSET MANAGEMENT, INC.

October 1, 2004

VIA ELECTRONIC TRANSMISSION

Mr. William Friar
Senior Financial Analyst
Securities and Exchange Commission
Division of Corporation Finance
450 Fifth Street, N.W.
Washington, D.C. 20549

Calamos Asset Management, Inc.
File No. 333-117847
Responses to SEC Comment Letter dated September 24, 2004

Dear Mr. Friar:

On behalf of Calamos Asset Management, Inc. (the "Company"), set
forth below are the comments of the staff of the Securities and Exchange
Commission (the "Commission") received in your letter dated September 24, 2004
relating to Amendment No. 1 ("Amendment No. 1") to the Company's registration
statement on Form S-1 (File No. 333-117847) filed on August 2, 2004 (as amended
to date, the "Registration Statement"), including the prospectus contained
therein (the "Prospectus"). Each comment is followed by the Company's response
to that comment. Capitalized terms used but not defined herein have the meanings
assigned to them in the Registration Statement.

This letter should be read in conjunction with the accompanying
Amendment No. 2 to the Registration Statement ("Amendment No. 2"), which the
Company filed with the Commission on the date hereof. In this letter, all page
references set forth in the Company's responses to the staff's comments refer to
page numbers in Amendment No. 2. To assist the staff in reviewing Amendment No.
2, we are delivering, by overnight mail to Mr. Clampitt, a copy of this letter
and eight bound copies of Amendment No. 2. Four of the copies of Amendment No. 2
have been marked to show changes from the Amendment No. 1.

By its responses herein and in Amendment No. 2, the Company believes
that it has addressed all of the comments of the staff of the Commission. The
Company is aware of its obligations under the Securities Act and will request in
writing an acceleration of the effective date of the Registration Statement. At
such time, the Company will, pursuant to the staff's

Mr. William Friar
October 1, 2004
Page 2

request, furnish a letter acknowledging the matters specified in the bullet
points included in the introductory paragraphs of your letter dated September
24, 2004.

General

1. The Company's failure to include key information in this amendment,
such as the number of shares being sold, a pricing range for their
sale, the percentage of the Company being sold, the cost to
terminate EAU Plan, no final management services agreement, no
future employment agreements with the senior managers and twenty-two
missing exhibits may result in the staff requiring significant time
after the filing of the next amendment to provide you with our
comments, and we may have significant comments and there may be many
of them pertaining to any part of the registration statement.

The Company acknowledges the staff's comment and has included most
of the key information requested by the staff, as well as most of
the missing exhibits.

2. The current disclosures do not appear to address the distribution of
current profits. Please revise the summary to indicate under
"Reorganization" how it will be determined who is entitled to the
current profits, i.e., profits in the year in which the
reorganization occurs.

The Company advises the staff that the stockholders of Calamos
Family Partners, Inc. will be entitled to all net profits of Calamos
Family Partners, Inc. recognized prior to the Reorganization. Net
profits or losses of Calamos Holdings LLC recognized from and after
the consummation of the Reorganization will be allocated to the
members of Calamos Holdings LLC pro rata in accordance with the
percentages of their respective equity interests. The Company has
revised the disclosure on page 3 of the Prospectus to include this
information.

Summary
Our Company

3. Revise the narrative after the penultimate paragraph to indicate the
Company initiated paying supplemental compensation payments to
selling agents and the date when that activity began. In addition,
disclose the aggregate compensation paid to selling agents in the
years ended December 31, 2001, December 31, 2003 and the period
ending June 30, 2004 as well as the portion that was supplemental
compensation during each of these periods.

The Company submits that, because its supplemental compensation
payments to third-party selling agents have been immaterial and
declining as a percentage of assets under management and revenues
and were not a contributing factor to the growth of the Company's
assets under management, a discussion of such payments is not
sufficiently material to investors in the Company's Class A

Mr. William Friar
October 1, 2004
Page 3

common stock to warrant including such a discussion in the "Summary"
section of the Prospectus. However, in response to the staff's
request, the Company has disclosed on page 46 of the Prospectus when
it first began making supplemental compensation payments. The
Company supplementally advises the staff that it did not initiate
these payments; rather the Company began making them at the request
of third-party selling agents. In addition, in response to the
staff's request, the Company has disclosed in MD&A in each
period-to-period discussion of operating expenses the amount of
supplemental compensation payments paid to third-party selling
agents (please see pages 51, 55 and 57 of the Prospectus). The
Company supplementally advises the staff that each period-to-period
discussion already quantifies distribution expense, which represents
payments (other than supplemental compensation payments) to
third-party selling agents for selling, underwriting, servicing and
administering the mutual funds managed by the Company. The Company
does not believe that aggregating distribution expense with
supplemental compensation expenses (which is a component of
marketing and sales promotion expense) would be meaningful to
investors and therefore has not presented these amounts on an
aggregate basis as requested by the staff.

Reorganization

4. With regard to your previous response number 9, please reconcile
your answer that the Calamos Family Partners will not derive any
revenues from the Company with the disclosure that the Company will
lease the future headquarters from Calamos Family Partners as well
as the yet to be filed Exhibit 10.9 (Management Services Agreement).
If Calamos Family Partners will derive future revenues from the
Company, provide disclosures of the nature and expected dollar
amounts of such revenues.

The Company confirms to the staff that it does not expect Calamos
Family Partners, Inc. to derive any revenues from the Company. The
Company advises the staff that, as disclosed on page 2 of the
Prospectus in the second paragraph under "Summary - Reorganization,"
pursuant to the Real Estate Distribution in June 2004, Calamos
Family Partners, Inc. distributed to its stockholders its interest
in all of its real estate assets, including the Company's existing
corporate headquarters. The stockholders of Calamos Family Partners,
Inc. thereafter contributed the real estate assets distributed to
them to a new limited liability company, Calamos Property Holdings
LLC, formed by them. That limited liability company is owned
directly by the stockholders of Calamos Family Partners, Inc. It is
not a subsidiary of Calamos Family Partners, Inc., and Calamos
Family Partners, Inc. has no ownership interest, direct or indirect,
in Calamos Property Holdings LLC.

Mr. William Friar
October 1, 2004
Page 4

Upon consummation of the offering, the Company expects to lease its
existing headquarters from a subsidiary of Calamos Property Holdings
LLC, and the Company also expects to lease its new headquarters,
upon completion thereof, from a subsidiary of Calamos Property
Holdings LLC. Calamos Family Partners, Inc. will not derive any
revenues from the Company's lease payments to a subsidiary of
Calamos Property Holdings LLC because Calamos Family Partners, Inc.
has no ownership interest in Calamos Property Holdings LLC or any of
its subsidiaries.

The Company further advises the staff that all payments expected to
be made under the Management Services Agreement will be made by
Calamos Family Partners, Inc. to the Company as consideration for
services provided by the Company. Calamos Family Partners, Inc.
therefore will not derive revenues from the Company pursuant to this
agreement.

The Offering
Use of Proceeds

5. We note your response that the Company plans to spend $30 million
for equipping the new headquarters prior to moving in mid-2005.
Please advise us why this is not a partial use of the proceeds from
this offering. In addition, please disclose the other expected
working capital uses.

The Company confirms to the staff that it does not expect to use any
of the proceeds of the offering to equip its new headquarters prior
to moving in mid-2005. The Company currently has and, even if it did
not consummate the offering, would expect to continue to have
sufficient cash on hand to equip its new headquarters. The Company
expects to use that cash, and not proceeds of the offering, for that
purpose.

The Company advises the staff that it currently is not able to
identify specific working capital purposes for which it may use
proceeds of the offering. The Company therefore has deleted from
pages 6 and 27 of the Prospectus references to working capital
as a potential use of proceeds and has revised the disclosure under
"Use of Proceeds" on page 27 to add more detail about the expected
use of proceeds.

Related to Our Industry
Our business and operations...

6. Revise the first narrative to use the penultimate sentence in the
first paragraph as the caption. In addition, delete the broad
discussion of how the Company is regulated to instead discuss the
various material proposed or recently enacted regulations that have
or could materially effect the business model of the Company. In
addition, the Company's response did not address the question as

Mr. William Friar
October 1, 2004
Page 5

to whether or not any clients or company personnel "engaged in" any
late trading or market timing activities. If so, please advise us of
the details.

The Company has revised the first risk factor on page 12 of the
Prospectus to use the penultimate sentence of the first paragraph as
the caption for the risk factor.

Pursuant to discussions with the staff, the Company has not revised
the risk factor in response to the second sentence of the staff's
comment, but instead has added disclosure on page 12 of the
Prospectus discussing indemnification for past violations of
applicable laws and regulations.

The Company supplementally advises the staff that it has policies
and procedures to prevent and detect late trading and short-term,
frequent trading. These policies and procedures include, among other
things, redemption fees, multi-layer reviews and exchange
limitations.

With regard to late-trading, the Company is unaware of any
shareholders that have been permitted to late-trade any shares of
the open-end funds managed by the Company. All orders for purchases,
redemptions or exchanges placed directly with the open-end funds
must be received prior to the close of regular session trading on
the New York Stock Exchange to receive that day's net asset value.
Shares of open-end funds managed by the Company may be purchased,
redeemed or exchanged through third-party selling agents. A
third-party selling agent who accepts such orders as agent of the
open-end funds must process those orders at the net asset value next
determined after the receipt of the order. Although the Company
cannot state with absolute certainty that no third-party selling
agent has accepted a late-trade, the Company's contracts with
third-party selling agents require that they adhere to the open-end
fund's prohibition against late-trading, and the Company has no
knowledge that any third-party selling agent has placed a late trade
order with any open-end funds managed by the Company.

With respect to short-term, frequent trading, the prospectuses of
the open-end funds managed by the Company state, "The Funds are
intended for long-term investment purposes only, and are not
intended for short-term or excessive trading. These practices may
disrupt portfolio management strategies and may increase expenses,
and thus harm fund performance." The prospectuses further state that
each "Fund may, in its discretion, suspend, and may permanently
terminate, the trading or exchange privileges of any investor who
engages in trading activity that it believes would be disruptive to
the Fund." The open-end funds managed by the Company have in the
past become aware of accounts that they believed to be engaged in
short-term, frequent trading. In accordance with the funds'
policies, they rejected or restricted those accounts. In fact, even
prior to the regulatory focus on this issue that began in the fall
of 2003, the open-end funds managed by the Company had restricted a
number of accounts believed to

Mr. William Friar
October 1, 2004
Page 6

be engaged in short-term, frequent trading. In addition, as is
disclosed in the Company's September 10, 2004 responses to the
staff's prior comments on this matter, the Company has not entered
into any agreements, whether formal or informal, to permit
short-term, frequent trading in any of the funds that it manages.

Our profit margins...

7. Revise to use the second sentence as the caption. In addition,
disclose the Company's fee structure as it compares to others in the
industry.

The Company has revised the second risk factor on page 12 of the
Prospectus to use the second sentence of the first paragraph as the
caption for the risk factor.

The Company advises the staff that although its investment
management fees vary from product to product, historically the
Company has competed primarily on the performance of its products
and not on the level of its investment management fees relative to
those of its competitors. (The Company has revised the risk factor
to include this disclosure.) As a result, the Company does not
believe that a comparison of its fees to the fees of its competitors
would be meaningful to investors in the Company's Class A common
stock, and the Company has not included an industry fee comparison
in its risk factor.

12b-1 fees

8. Revise to disclose that if 12b-1 fees are eliminated the Company
would have to write-off its deferred sales commissions and recognize
an expense of $58.6 million at June 30, 2004.

The Company has revised page 14 of the Prospectus pursuant to the
staff's comments.

Soft dollars

9. Noting the Company has eliminated the risk factor, and with a view
towards adding another risk factor, supplementally advise the staff
if the Company has any arrangements or has steered any business to
brokerage firms for promoting its funds as part of deals known in
the industry as "revenue sharing" or "shelf space". If so, advise us
as to the brokerages involved and the amount of commissions received
by each brokerage. In addition, advise us if the funds disclosed
these type arrangements with their clients and, if so, provide us
with a sample of such disclosure.

The Company supplementally advises the staff that it has no
arrangements and has not steered any business to brokerage firms for
promoting its funds as part of the transactions referred to in the
staff's comment.

Mr. William Friar
October 1, 2004
Page 7

Third-party distribution

10. Supplementally advise the staff if any of the referred to
"third-party vendors" are brokerage firms or selling agents used by
the Company.

Pursuant to discussions with the staff, the Company understands that
the intended reference in the staff's comment is to the second risk
factor on page 18 of the Prospectus. The Company advises the staff
that the "third-party vendors" referred to in that risk factor
generally do not include brokerage firms or selling agents used by
the Company. However, the Company further advises the staff that,
although US Bancorp is primarily responsible for providing transfer
agent services with respect to open-end funds managed by the
Company, certain selling agents used by the Company perform some
sub-transfer agent services with respect to shares of open-end funds
for which they act as intermediaries. The Company believes that the
risk associated with these selling agents failing to perform their
sub-transfer agent services is covered by the language of the risk
factor.

Use of Proceeds

11. Revise to include the information requested by Comment 4 above.

The Company has revised its disclosure as discussed in response to
that Comment No. 5 above.

MD&A
Year ended 12/31/03

12. The explanation for the increase in net purchases discloses no
changes in the compensation (fees and commissions) paid to attract
those purchases. If true, indicate no changes in the compensation
rates occurred from the year ended 12/31/02 or otherwise disclose
any such changes.

Pursuant to discussions with the staff, the Company has revised the
discussion of distribution expenses on pages 51, 55 and 57 of
the Prospectus to disclose that the rates paid in the current period
did not change from the rates paid in the prior year period.

13. Revise to make similar disclosures in the "Revenue" and "Operating
Expenses" sections that follow.

Pursuant to discussions with the staff and as indicated in response
to Comment No. 12 above, the Company has made the requested
disclosure in the "Operating Expenses" section.

Mr. William Friar
October 1, 2004
Page 8

Year ended 12/31/02

14. Make disclosures in the appropriate sections consistent with
comments 11-12.

As discussed in response to Comment Nos. 12 and 13, the Company has
made the requested disclosure in the "Operating Expenses" section.

Liquidity and Capital Resources

15. Revise the second paragraph on page 56. We note the paragraph is
referring to amortization, not cash flows or the balance sheet.
Revise accordingly.

The Company previously revised its disclosure in response to the
staff's request. The revisions appear in the second full paragraph
on page 59 of the Prospectus.

16. Noting the cash used for construction payments in the third
paragraph on page 56, supplementally advise the staff of the
arrangement for the new headquarters, such as, how much is owed to
complete, when will it be complete, who will pay the remaining
costs, will the Company then lease the building and what will be the
costs to the Company.

The Company refers the staff to the Company's response to Comment
No. 44 in the staff's comment letter dated September 2, 2004.

Business
Business Strategy

17. Supplementally advise us if the funds' reports to holders disclose
that the funds engage in portfolio hedging activities and, if so,
provide us with an example of such disclosure.

The Company advises the staff that the funds provide their
shareholders with information in connection with the funds' short
sales and other hedging activities, if any, to the extent required
by Item 21(b)(7)(i) of Form N-1A "Management's Discussion of Fund
Performance." This Item requires the Company to discuss in the
funds' annual reports the factors that materially affected the
funds' performance, including investment strategies and techniques.
Because short sales (and other hedging strategies) were not a
material factor affecting the funds' performance, other than the
Market Neutral Fund, such a discussion was not required or included
in the shareholder reports for those funds. The Company advises the
staff that a discussion of short sales was provided for the Market
Neutral Fund on page 22 and on page 65 in Note 5 of the Notes to
Financial Statements of the open-end funds' annual report to
shareholder for the fiscal year ended March 31, 2004. Copies of
pages 22 and 65 of the annual report are attached hereto as Annex A.
(The Company also advises the staff that each fund

Mr. William Friar
October 1, 2004
Page 9

is permitted to engage in short sales as set forth in the funds'
statement of additional information.)

Certain U.S. Federal Tax Considerations for Non-U.S. Holders - page 101

18. We continue to believe that if you have tax information for non-U.S.
holders, you should balance this section with a comparable section
for U.S. holders.

The Company has included additional disclosure on pages 108 through
111 of the Prospectus in response to the staff's request.

Underwriting

19. Revise to disclose the present intentions of those participating in
the Directed Share program as to how many shares they intend to
purchase.

The Company advises the staff that it does not presently know the
aggregate number of shares of Class A common stock that participants
in the directed share program intend to purchase in the offering.
The Company will disclose that number when it is known to the
Company.

Accounting Comments
General

20. Please include a signed and currently dated accountants' consent in
further pre-effective amendments.

The Company will continue to file signed and currently dated
accountants' consents with further pre-effective amendments to the
Registration Statement.

Summary Historical and Pro Forma Consolidated Financial and Other Data - page 9

21. In your response to our prior comments 64 and 67 related to pro
forma earnings per share you state that disclosures had been revised
pursuant to our comments. We note that the requested disclosures are
incomplete and accordingly reissue our prior comments.

The Company has revised and completed its disclosure pursuant to the
staff's request.

Notes to Pro Forma Consolidated Financial Statements - page 36

22. We continue to await your presentation of pro forma financial
information based upon factually supportable adjustments as required
by Rule 11-02 of Regulation S-X. We may have further comments.

Mr. William Friar
October 1, 2004
Page 10

The Company has revised and completed its pro forma disclosure
pursuant to the staff's request.

23. We note your response to our prior comment 70. Please revise note
(3) to explain how you determined the amounts of each of the
adjustments directly attributable to the Real Estate Distribution
that are factually supportable and expected to have a continuing
impact. Explain why you expect to reduce employee compensation and
benefits as a result of the Real Estate Distribution.

The Company has revised its disclosure pursuant to the staff's
comments.

24. We note your response to our prior comment 73 and the revised
disclosure on page 36. Supplementally explain to us how you
determined the "recharacterization of compensation in the form of
equity distributions to owners" in the amount of $1.6 million to be
(i) directly attributable to the transaction, (ii) expected to have
a continuing impact on your operating results, and (iii) factually
supportable.

The Company supplementally advises the staff that the
recharacterization, as compensation, of equity distributions to
owners in the amount of $1.6 million is directly attributable to the
Reorganization because Calamos Family Partners, Inc. historically
operated as an S corporation and, as a result, Calamos Family
Partners, Inc. had the flexibility to pay a portion of owners'
compensation through dividends during 2003. Upon consummation of the
Reorganization, the Company will be taxable as a C corporation. No
portion of owners' compensation would have been paid through
dividends during 2003 if Calamos Family Partners, Inc. had been
taxable as a C corporation in 2003. The Company further advises the
staff that the Reorganization is being undertaken solely to
facilitate the offering.

The Company further advises the staff that the events resulting in
the recharacterization, namely the offering and related
Reorganization, are expected to have a continuing impact on the
Company because, as discussed above, upon consummation of the
Reorganization, the Company will be taxable as a C corporation.
Accordingly, the Company does not expect to pay compensation to
owners through dividends after consummation of the Reorganization.

Finally, the Company advises the staff that the amount
recharacterized is factually supportable because the Company's
employee compensation and benefits, including the compensation of
the Company's executive officers, are based on industry standards as
determined by a third-party survey commissioned by the Company.

Mr. William Friar
October 1, 2004
Page 11

Management's Discussion and Analysis of Financial Condition and Results of
Operations Investment Products - Mutual Funds - page 41

25. For each class of shares of the open-end funds, please revise to
separately disclose Rule 12b-1 distribution fee and shareholder
service fee percentages received by you and paid to third-party
selling agents.

The Company has revised its disclosure on pages 42 and 43 of the
Prospectus pursuant to the staff's comments.

26. We note that you make annual payments of 1% of Class C share assets
under management to third party selling agents. Given that
distribution fees are capped at 0.75% of assets under management,
describe the services that the third-party selling agents are
performing on a continuing basis that entitles them to participate
in the shareholder service fee.

The Company supplementally advises the staff that third-party
selling agents are entitled to receive a shareholder service fee
pursuant to an open-end funds' distribution plan and relevant
contracts by performing certain ongoing services for shareholders
such as, among other things, answering shareholder inquiries about
the funds, assisting shareholders in changing account designations
and addresses and assisting shareholders in processing purchase and
redemption transactions.

Year Ended December 31, 2003 Compared to Year Ended December 31, 2002
Operating Expenses - page 52

27. We note your revised disclosures on page 52 that Class C shares do
not generate a distribution expense in the first year. Please revise
to explain how you account for the retained Rule 12b-1 fees and
upfront paid sales commissions in the first year.

The Company has revised its disclosure pursuant to the staff's
comments; however, because the disclosure requested by the staff
applies to both Class B and Class C shares, the Company has revised
the descriptions of those share classes on pages 42 and 43 of the
Prospectus instead of revising page 52 as requested by the staff.

28. Please revise to individually quantify and comprehensively discuss
the impact of growth of open-end fund assets under management and
the aging of Class C shares on the 183% increase in distribution
expense.

The Company has revised its disclosure on pages 51, 54-55 and 57 of
the Prospectus pursuant to the staff's comments.

Mr. William Friar
October 1, 2004
Page 12

Recently Issued Accounting Pronouncements - page 60

29. We note your revised disclosures and responses to our prior comments
83-86. Your reliance on redemption rights to not consolidate Calamos
Multi-Strategy, L.P. prior to the amendment of the limited
partnership agreement in 2004 does not appear to meet the "important
rights" criteria specified in paragraph 9 of SOP 78-9. Please revise
to specify the 2004 amendment date and consolidate the results of
Calamos Multi-Strategy, L.P. for all periods prior to this amendment
date, or advise us.

As discussed with the accounting staff, the Company submits that for
all periods presented, the Company concluded that the limited
partners had sufficient rights, including redemption rights, that
allowed the Company to account for its interest in Calamos
Multi-Strategy L.P. using the equity method of accounting as
prescribed by AICPA Statement of Position 78-9. The issues of what
constitutes "important rights" and other related accounting matters
are currently under discussion by the Emerging Issues Task Force
(EITF Issue No. 04-05). The key issue is described in the current
EITF Agenda Issue Summary as follows: "Very little authoritative
guidance exists for purposes of making an assessment about whether a
limited partner's rights are important rights. As a result, views in
practice about what rights constitute important rights have evolved
over time".

As a result of the recent accounting views on this matter, including
deliberations on EITF Issue No. 04-05, the Company was proactive in
amending the limited partnership agreement for Calamos
Multi-Strategy L.P. during 2004. Specifically, the Company made a
decision to expand the rights of the limited partners in line with
the current discussion topic, including providing simple majority
vote of the limited partners, excluding related parties. In
addition, according to the current views regarding transition
express in the issue discussion EITF Issue No. 04-05, we believe
there would be no change to historical reported amounts since the
partnership agreements have been appropriately modified by the dates
indicated.

Additionally, the Company has revised its disclosure pursuant to the
recent accounting pronouncements to indicate that its limited
partnership agreement was amended on September 1, 2004.

Note 2 - Summary of Accounting Policies - Revenue Recognition - page F-9

30. We note your revised disclosures in response to our prior comment
99. Supplementally confirm that the recorded Rule 12b-1 fee revenue
does not materially differ from the actual receipt of Rule 12b-1
fees and your current accounting complies with the guidance provided
in EITF 85-24.

The recorded Rule 12b-1 fee revenue does not differ from the actual
receipt of Rule 12b-1 fees because the Company accrues the fee based
on the actual receipt of the fee, which occurs on the second
business day following month end. The Company's current accounting
complies with EITF 85-24 (Distribution Fees by Distributors of
Mutual Funds that do not have a front-end sales charge) by using the
cost deferral method, which states that fees should be recognized
when received.

31. Supplementally tell us how you determined that gross revenue
recognition is appropriate for each component of the Rule 12b-1
fees, i.e. distribution fees and

Mr. William Friar
October 1, 2004
Page 13

shareholder service fees. Tell us who you believe the customer is in
each arrangement and explain how you made this determination.

The Company believes that gross revenue recognition is appropriate
for both the distribution fee component and the service fee
component of the Rule 12b-1 fee because in each instance the
open-end fund's obligation, pursuant to the Rule 12b-1 plan, to make
distribution and service fee payments to the Company is a separate
and distinct obligation from the Company's obligation, pursuant to
its various selling agreements, to make distribution or service fee
payments to such selling agents. The Company is the primary obligor
to each open-end fund with respect to distribution and shareholder
servicing, negotiates the fee for those services and has the
discretion to select the selling agents. As such, all distribution
and service fees are recorded gross without deducting any
distribution or service fees paid to third-party selling agents.

- - Investments in Partnerships - page F-9

32. We note your revised disclosure in response to our prior comment 88.
Please revise to describe how you accounted for the sale of your
investment in Calamos Hedge Fund, L.P.

The Company has revised its disclosure on page F-10 of the
Prospectus pursuant to the staff's comments.

33. Please revise footnote 1 to also identify non-corporate entities
that are included in your consolidated financial statements.

The Company has revised the "Principles of Consolidation" under
footnote (2) on page F-7 of the Prospectus to add further disclosure
regarding the consolidation of Calamos Hedge Fund, L.P. The Company
does not believe that a discussion of the consolidation of Calamos
Hedge Fund, L.P. would be appropriate in footnote (1), as the
results of Calamos Hedge Fund, L.P. are immaterial to the Company's
operations and footnote (1) is intended to discuss the material
components of the Company's business.

Other Comments

34. Several of your responses regarding Investment Company issues have
been forwarded to the Division of Investment Management for their
review. If there are additional comments, we will forward those to
you upon our receipt.

The Company acknowledges the staff's comment.

35. With regard to the issue of "naked shorts" as discussed in the
Underwriting section and your response that naked shorts may be used
to "facilitate an orderly distribution by creating buying power",
supplementally advise us how the use of

Mr. William Friar
October 1, 2004
Page 14

naked shorts accomplishes this. In addition, advise us if your
underwriters have previously sold naked shorts in an IPO and, if so,
provide us with an explanation/illustration as to how that supported
the price. We may have further comment.

Any short sale position created by over-alloting securities
increases overall demand for the stock as underwriters must close
out the short position to be able to deliver shares. The
underwriters may choose to cover the short position in whole or in
part by exercising any over-allotment option that the issuer has
granted to them. If the underwriters have over-alloted more shares
than may be covered by the over-allotment option, then they must
close out the naked short by purchasing shares in the open market.

The underwriters have previously sold naked shorts in an IPO. In
such situations, the underwriters were concerned that the supply of
securities offered for sale in the secondary market after the
commencement of trading of the securities offered in the IPO might
exceed the demand to purchase such securities, thereby creating
downward pressure on the price of the securities that could
adversely affect the investors who have purchased in the IPO. The
underwriters' experience leads them to believe that purchases to
cover the naked short may have had the effect of preventing or
retarding a decline in the price of the securities that might
otherwise occur in the absence of such purchases.

If you have any questions concerning the matters referred to in this
letter, please call the undersigned at (630) 245-7296 or counsel to the Company,
Michael Schiavone of Shearman & Sterling LLP, at (212) 848-4813.

Very truly yours,

/s/ James S. Hamman, Jr.
-------------------------
James S. Hamman, Jr.

cc: Michael Clampitt
(Securities and Exchange Commission)
Michael Schiavone
(Shearman & Sterling LLP)

ANNEX A

MARKET NEUTRAL FUND

A SHARES, AS OF 3/31/2004
SYMBOL
CVSIX
INCEPTION DATE
September 4, 1990

[MORNINGSTAR(TM) LOGO]
****
OVERALL RATING
Among 199 Conservative
Allocation Funds+

For the 3-, 5-, and 10-year periods ended 3/31/04, the Fund's Class A shares
received four stars for three years, five stars for five years, and four stars
for ten years among 199, 146, and 40 conservative allocation funds respectively.

The CALAMOS Market Neutral Fund achieved a return of 10.11% (A
shares, before sales charge) for the fiscal year ending 3/31/04 well ahead of
the Lehman Brothers Government/Corporate Bond Index, which returned 6.15%, the
Lipper Flexible Income Fund Average of 7.34%, and the Citigroup 30-Day Treasury
Bill Index, which returned 0.96%. The Fund retains its ranking as the #1
Flexible Income Fund for both five years (out of 8 funds) and 10 years (out of 6
funds), as of 3/31/04 according to Lipper.*

The Fund employs a "convertible arbitrage" strategy, designed to
take advantage of discrepancies between how the market prices two different
types of securities issued by the same company: common stock and convertible
bonds. Generally, the Fund will simultaneously go "long" (anticipate a rise) on
the convertible and go "short" (anticipate a decline) on the stock. The
offsetting strategy is intended to produce lower volatility than the broader
market, while still generating gains.

CALAMOS Market Neutral Fund remains closed to most investments,
except as enumerated in the prospectus. This closure is intended to enable the
portfolio management team to manage the Fund efficiently, and the closure will
remain in effect until the managers believe that they can accept new assets
without adversely affecting the performance of the Fund.

We believe that the Fund will continue to serve shareholders seeking
a conservative income investment and can help diversify portfolios with returns
that historically are not correlated to those of the broader market.

* #10 for 1 year out of 16 flexible income funds. Source: Lipper Analytical
Services, Inc. Lipper rankings are based on net total return performance, and do
not reflect the effect of sales charges; if they had, results may have been less
favorable.

+ Morningstar proprietary ratings on U.S.-domiciled funds reflect historical
risk-adjusted performance and are subject to change every month. Ratings are
calculated from a fund's 3-, 5-, and 10-year average annual returns in excess
of 90-day T-bill returns with appropriate fee adjustments and a risk factor that
reflects fund performance below 90-day T-bill returns. The Overall Morningstar
Rating is a weighted average based on the 3-, 5-, and 10-year risk-adjusted
performance. The top 10% of funds in an investment category receive five stars,
the next 22.5% receive four stars, the next 35% receive three stars, the next
22.5% receive 2 stars, and the bottom 10% receive 1 star. Ratings reflect the
effect of sales charges.

NOTES TO FINANCIAL STATEMENTS

As of March 31, 2004, the funds had capital loss carryforwards which, if not
used, will expire as follows:

GLOBAL HIGH MARKET
GROWTH BLUE CHIP VALUE GROWTH AND GROWTH AND YIELD CONVERTIBLE NEUTRAL
FUND FUND FUND INCOME FUND INCOME FUND FUND FUND FUND
- ---------------------------------------------------------------------------------------------------------------------------------

2011 $(11,154,218) $-- $(28,858) $-- $-- $-- $-- $--
------------ --- -------- --- --- --- --- ---
(11,154,218) -- (28,858) -- -- -- -- --
------------ --- -------- --- --- --- --- ---

The funds had deferred post-October losses occurring subsequent to October 31,
2003. For tax purposes, such losses will be treated as having occurred on April
1, 2004. As of March 31, 2004, post-October losses are as follows:

Capital $-- $(20,360) $-- $ -- $ (507,072) $-- $ -- $--
Currency -- -- -- (9,583) (1,617,679) -- (3,375,205) --
--- -------- --- ------- ----------- --- ----------- ---
-- (20,360) -- (9,583) (2,124,751) -- (3,375,205) --
--- -------- --- ------- ----------- --- ----------- ---

NOTE 5 - SHORT SALES

Securities sold short represent obligations to purchase the securities at a
future date at then prevailing prices. The transactions result in
off-balance-sheet risk (i.e., the risk that the ultimate obligation may exceed
the amount shown in the accompanying statement of assets and liabilities). To
the extent a Fund owns equivalent securities, the off-balance-sheet risk is
offset. During the year ended March 31, 2004, the Market Neutral Fund incurred
net losses of $105,749,841 on short sales that were classified as net realized
gain (loss) on investments, options and foreign currency contracts. No other
Fund engaged in short sales during the year ended March 31, 2004.

NOTE 6 - FORWARD FOREIGN CURRENCY CONTRACTS

Each Fund may engage in portfolio hedging with respect to changes in currency
exchange rates by entering into foreign currency contracts to purchase or sell
currencies. A forward foreign currency contract is a commitment to purchase or
sell a foreign currency at a future date at a negotiated forward rate. Risks
associated with such contracts include movement in the value of the foreign
currency relative to the U.S. dollar and the ability of the counterparty to
perform. The net unrealized gain, if any, represents the credit risk to the Fund
on a forward foreign currency contract. The contracts are valued daily at

forward exchange rates and an unrealized gain or loss is recorded. The Fund
realizes a gain or loss upon settlement of the contracts. The statement of
operations reflects net unrealized gains and losses on these contracts. The
counterparty to all forward foreign currency contracts at March 31, 2004, was a
multinational bank.

As of March 31, 2004 the Global Growth and Income Fund had the following open
forward foreign currency contracts:

SETTLEMENT LOCAL CURRENT UNREALIZED
DATE CURRENCY VALUE GAIN (LOSS)
- -----------------------------------------------------------------------------------------------------------------------

Short Contracts
Australian Dollar 4/22/2004 1,100,000 $ 837,532 $ 4,188
British Pound Sterling 4/22/2004 8,710,000 15,976,011 (114,313)
Canadian Dollar 4/22/2004 1,620,000 1,231,899 7,486
Danish Krone 4/22/2004 19,250,000 3,175,853 41,642
Euro 4/22/2004 25,925,000 31,836,625 721,959
Hong Kong Dollar 4/22/2004 19,950,000 2,562,423 11,638
Japanese Yen 4/22/2004 895,000,000 8,610,722 (218,599)
Norwegian Kroner 4/22/2004 9,160,000 1,333,931 (3,389)
South Korean Won 4/22/2004 708,000,000 616,503 (24,955)
Swedish Krona 4/22/2004 9,750,000 1,292,386 39,377
Swiss Franc 4/22/2004 13,500,000 10,665,014 213,077
Taiwanese Dollar 4/22/2004 46,675,000 1,421,167 (28,521)
-----------
$ 649,590