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