FOXBY CORP. 11 Hanover Square New York, New York 10005 July 20, 2007 Securities and Exchange Commission 450 Fifth Street, N.W. Washington, DC 20549 Re: Foxby Corp. Commission File No. 811-09261 Proxy Solicitation Material for Annual Meeting of Stockholders Ladies and Gentlemen: On behalf of Foxby Corp. (the "Fund"), transmitted herewith for filing via the EDGAR filing system are the preliminary forms of the Notice of Annual Meeting of Stockholders and Proxy Statement (the "Annual Meeting Proxy Statement") and Proxy on Schedule 14A in connection with the Fund's Annual Meeting of Stockholders in the form in which that material is expected to be furnished to stockholders. Should you have any questions or comments concerning the Annual Meeting Proxy Statement, please contact R. Darrell Mounts, Esq. of Kirkpatrick & Lockhart Preston Gates Ellis LLP, counsel to the Fund, at 1-202-778-9298. Very truly yours, /s/ John F. Ramirez ------------------- John F. Ramirez Secretary Enclosures VIA EDGAR