David James
PFPC Inc.
Vice President and Counsel
99 High Street, 27th Floor
Boston, MA 02110
(617) 338-4595

(617) 338-4864 - fax

December 20, 2007

VIA EDGAR
Securities and Exchange Commission
100 F Street NE
Washington, D.C. 20549

RE: The Gabelli Asset Fund GAMCO International Growth Fund, Inc.
 File Nos.: 33-1719/811-4494 File Nos.: 33-79994/811-08560
 The Gabelli Blue Chip Value Fund Gabelli Investor Funds, Inc.
 File Nos.: 333-80099/811-09377 File Nos.: 33-54016/811-07326
 Gabelli Capital Series Funds, Inc. The GAMCO Mathers Fund
 File Nos.: 33-61254/811-7644 File Nos.: 002-23727/811-01311
 Comstock Funds, Inc. The Gabelli Global Utility & Income Trust
 File Nos.: 33-40771/811-05502 File Nos.: 333-113621/811-21529
 The Gabelli Convertible and Income Securities Fund Inc.
 File Nos.: 333-24541/811-05715
 Gabelli Equity Series Funds, Inc. The Gabelli Money Market Funds
 File Nos.: 33-41913/811-06367 File Nos.: 33-48220/811-6687
 The Gabelli Equity Trust Inc. The Gabelli Dividend & Income Trust
 File Nos.: 33-42780/811-4700 File Nos.: 333-126480/811-21423
 The Gabelli Global Deal Fund The Gabelli Utilities Fund
 File No. 333-138141/811-21969 File Nos.: 333-81209/811-09397
 The Gabelli Global Multimedia Trust Inc. The Gabelli Utility Trust
 File Nos.: 333-25487/811-08476 File Nos.: 333-72983/811-09243
 GAMCO Global Series Funds, Inc. The Gabelli Value Fund Inc.
 File Nos.: 33-66262/811-07896 File Nos.: 33-30139/811-5848
 GAMCO Gold Fund, Inc. The Westwood Funds
 File Nos.: 33-79180/811-08518 File Nos.: 33-06790/811-04719
 The GAMCO Growth Fund The Gabelli Healthcare & WellnessRx Trust
 File Nos.: 33-10583/811-4873 File Nos.: 333-140966/811-22021
 The Gabelli Global Gold, Natural Resources The Gabelli SRI Fund, Inc.
 & Income Trust File Nos.: 333-141093/811-22026
 FILE Nos.: 333-121998/811-21698 (THE "FUNDS")

Dear Staff Member:

Pursuant to Rule 17g-1(g)(1) under the Investment Company Act of 1940, as amended, enclosed for filing on behalf of the above-referenced Funds please find (i) one copy of a rider for an increase in coverage for their joint fidelity bond (the "Joint Bond") for the policy period from December 7, 2006 to December 7, 2007, such policy being maintained through National Union Fire Insurance Company, (ii) an Assistant Secretary's Certificate certifying the resolutions adopted by each Fund's Board Members approving the amount, type, form and coverage of the Joint Bond and the portion of the premium to be paid by the Funds and (iii) the Amended and Restated Joint Insured Agreement among the Funds and the other insureds on the Joint Bond.


The Joint Bond premium allocation for the increase in coverage for these Funds has already been paid.

Very truly yours,

/S/ DAVID JAMES
------------------
David James
Assistant Secretary

Enclosures


ASSISTANT SECRETARY'S CERTIFICATE

I, David James, Assistant Secretary of The Gabelli Asset Fund, The Gabelli Blue Chip Value Fund, Gabelli Capital Series Funds, Inc., Comstock Funds, Inc., The Gabelli Convertible and Income Securities Fund Inc., The Gabelli Dividend & Income Trust, Gabelli Equity Series Funds, Inc., The Gabelli Equity Trust Inc., The Gabelli Global Deal Fund, The Gabelli Gold, Natural Resources & Income Trust, The Gabelli Global Multimedia Trust Inc., GAMCO Global Series Funds, Inc., The Gabelli Global Utility & Income Trust, GAMCO Gold Fund, Inc., The GAMCO Growth Fund, The Gabelli Healthcare & WellnessRx Trust, GAMCO International Growth Fund, Inc., Gabelli Investor Funds, Inc., The GAMCO Mathers Fund, The Gabelli Money Market Funds, The Gabelli SRI Fund, Inc., The Gabelli Utilities Fund, The Gabelli Utility Trust, The Gabelli Value Fund Inc. and The Gabelli Westwood Funds (the "Funds"), hereby certify that the following resolutions have been adopted first by those Board Member who are not considered to be "interested persons," as defined in the Investment Company Act of 1940, as amended (the "1940 Act")("Independent Board Members") voting separately, and then by the entire Board of each Fund, at a meeting duly called and held on November 13, 2007:

RESOLVED, That after having given due consideration to
 all relevant factors, the Board Members,
 including all of the Independent Board
 Members, hereby approve the amendment to the
 existing joint fidelity bond coverage with
 National Union Fire Insurance Company, and
 ratify, confirm and approve an increase in
 the amount of coverage under said joint
 fidelity bond from $23,025,000 to
 $24,600,000 effective as of November 13,
 2007; and further

RESOLVED, That the portion of the increased premium
 for the aforementioned joint insured
 fidelity bond to be paid by the Fund, if
 any, is hereby approved, taking into
 consideration, among other things, the
 number of parties named as insureds; the
 nature of the business activities of such
 other parties; the amount of the joint
 insured bond; the amount of the premium for
 such bond; the ratable allocation of the
 premium among all parties named as insureds;
 and the extent to which the share of the
 premium allocated to the Fund is less than
 the premium the Fund would have had to pay
 if it had provided and maintained a single
 insured bond; and further

RESOLVED, That the Assistant Secretary of the Fund is
 hereby authorized and directed to prepare,
 execute and file such supplements to the

fidelity bond, and to take such action as may be necessary or appropriate in order to conform the terms of the fidelity bond coverage to the provisions of the 1940 Act, and the rules and regulations promulgated thereunder.

IN WITNESS WHEREOF, the undersigned has hereunto set his hand this 20th day of December, 2007.

/S/ DAVID JAMES
--------------------
David James
Assistant Secretary


NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA

Rider No. 13

To be attached to and form part of Investment Company Blanket Bond No. 6214219 in favor of The Gabelli Funds, et al.

1. In consideration of the additional premium of $737.00, it is hereby understood and agreed that Item 3 of the Declaration Page is deleted in its entirety and replaced with the following:

ITEM 3 Limit of Liability - Subject to Section 9, 10, and 12 hereof:

 Limit of Liability Deductible Amount
 Insuring Agreement A - FIDELITY $24,600,000 $0
 Insuring Agreement B - AUDIT EXPENSE $25,000 $5,000
 Insuring Agreement C - ON PREMISES $24,600,000 $10,000
 Insuring Agreement D - IN TRANSIT $24,600,000 $10,000
 Insuring Agreement E - FORGERY OR ALTERATION $24,600,000 $10,000
 Insuring Agreement F - SECURITIES $24,600,000 $10,000
 Insuring Agreement G - COUNTERFEIT CURRENCY $24,600,000 $10,000
 Insuring Agreement H - STOP PAYMENT $25,000 $5,000
 Insuring Agreement I - UNCOLLECTIBLE ITEMS
 OF DEPOSIT $25,000 $5,000

OPTIONAL COVERAGES ADDED BY RIDER:

 Insuring Agreement J - COMPUTER SYSTEMS $24,600,000 $10,000
 Insuring Agreement K - UNAUTHORIZED SIGNATURES $25,000 $5,000
 Insuring Agreement L - AUTOMATED PHONE SYSTEMS $24,600,000 $10,000
 Insuring Agreement M - TELEFACSIMILE $24,600,000 $10,000

If "Not Covered" is inserted above opposite any specified Insuring Agreement or Coverage, such Insuring Agreement or Coverage and any other reference thereto in this bond shall be deemed to be deleted therefrom.

2. Nothing herein shall be held to vary, alter, waive or extend any of the terms, limitations, conditions or provisions of the attached bond other than as above stated.

3. This rider shall become effective as of 12:01 a.m. on 09/30/07 standard time as specified in the attached bond.

By:

Authorized Representative


AMENDED AND RESTATED

JOINT INSURED AGREEMENT

AGREEMENT dated December 1, 1999, as most recently amended as of May 15, 2007, among the registered investment companies advised by Gabelli Funds, LLC, Gabelli Advisers, Inc. and Gabelli Fixed Income LLC (together, the "Advisers") which are listed on Schedule A attached hereto (collectively, the "Funds").

WHEREAS, each of the Funds is named as an insured in an investment company blanket bond (the "Fidelity Bond") which is intended to be in full compliance with Rule 17g-1 under the Investment Company Act of 1940, as amended; and

WHEREAS, the Funds desire to enter into an agreement in order to meet the requirements of Rule 17g-1 and to assure that premiums payable with respect to the Fidelity Bond and payments by the Insurer with respect to the Fidelity Bond are allocated in a fair and equitable manner;

Now, THEREFORE, the Funds do hereby agree as follows:

1. Each Fund shall maintain a minimum amount of fidelity insurance one level higher than that specified for its asset size by the table contained in Rule 17g-1(d) (the "Minimum Insurance"). Each Fund shall aggregate the assets of all of its series to calculate the amount of coverage required by Rule 17g-1(d). Notwithstanding the foregoing, no Fund shall be required to increase the amount of its fidelity insurance unless and until the aggregate amount of fidelity insurance maintained by the Funds exceeds the aggregate amount of fidelity insurance the Funds are required to maintain pursuant to the table contained in Rule 17g-1(d) by $2 million or less.

2. The allocation of the premium to each Fund shall be based on the proportionate share of the sum of the premiums that would have been paid if fidelity insurance was purchased separately by the Funds, and will be based upon the relative Minimum Insurance percentages of the Funds as of the quarter ending prior to the beginning of the first month in the period for which the coverage is obtained, subject to paragraph 4 below.

3. Each Fund is guaranteed a minimum coverage amount with access to the remainder of the total coverage of the Fidelity Bond. In the event that any recovery is received under the Fidelity Bond as a result of the loss sustained by two or more Funds, each Fund shall receive an equitable and proportionate share of the recovery, but in no event less than the amount it would have received had it maintained a single insured bond with minimum coverage.

4. Each Fund may, at any time, increase its allocation described in paragraph 2 upon payment of the premium required for such additional insurance provided that the face amount of the Fidelity Bond can increase accordingly or be supplemented by a policy of excess insurance.


5. Any other registered investment company or additional series of such an investment company for which the Advisers or their affiliates serves as investment adviser ("Additional Fund") may become a party to this Agreement by executing a copy of this Agreement (a copy of which will be furnished to each of the Funds) and by paying the premium for any required increase in the amount of the Fidelity Bond if the underwriter of the Fidelity Bond is willing to add such Additional Fund as an additional insured and increase the amount of total coverage by the amount of the Minimum Insurance required for such Additional Fund by the provisions hereof.

6. The Agreement shall remain in effect for as long as two or more of the Funds (including any Additional Fund) are insured under the terms of the Fidelity Bond. Any Fund shall, however, have the right to terminate, at any time, its participation in the Fidelity Bond and in this Agreement provided that losses incurred prior to such termination shall be governed by the provision of this Agreement and the amount of any return premium to which such Fund shall be entitled will be limited to the amount actually obtained from the underwriter in respect of such termination.

Signed: /S/ BRUCE N. ALPERT
 Bruce N. Alpert

 President, The Gabelli Asset Fund
 President, The Gabelli Blue Chip Value Fund
 President, Gabelli Capital Series Funds, Inc.
 Executive Vice President, Comstock Funds, Inc.
 President, The Gabelli Convertible and Income Securities Fund Inc.
 President, The Gabelli Dividend & Income Trust
 President, Gabelli Equity Series Funds, Inc.
 President, The Gabelli Equity Trust Inc.
 President, The Gabelli Global Deal Fund
 President, The Gabelli Global Gold, Natural Resources & Income Trust
 President, The Gabelli Global Multimedia Trust Inc.
 President, GAMCO Global Series Funds, Inc.
 President, The Gabelli Global Utility & Income Trust
 President, GAMCO Gold Fund, Inc.
 President, The GAMCO Growth Fund
 President, GAMCO International Growth Fund, Inc.
 President, Gabelli Investor Funds, Inc.
 Executive Vice President, The GAMCO Mathers Fund
 President, The Gabelli Money Market Funds
 President, The Gabelli SRI Fund, Inc.
 President, The Gabelli Utilities Fund
 President, The Gabelli Utility Trust
 President, The Gabelli Value Fund Inc.
 President, The Westwood Funds

Signed: /S/ AGNES MULLADY
 Agnes Mullady
 President, The Gabelli Healthcare & Wellness(Rx) Trust


SCHEDULE A

LIST OF REGISTERED INVESTMENT COMPANIES

The Gabelli Asset Fund
The Gabelli Blue Chip Value Fund The Gabelli Convertible Securities and Income Securities Fund Inc. The Gabelli Dividend & Income Trust The Gabelli Equity Trust Inc. The Gabelli Global Deal Fund
The Gabelli Global Gold, Natural Resources & Income Trust The Gabelli Healthcare & Wellness(Rx) Trust The Gabelli Global Multimedia Trust Inc. The Gabelli Global Utility & Income Trust GAMCO Gold Fund, Inc.
The GAMCO Growth Fund
GAMCO International Growth Fund, Inc. The GAMCO Mathers Fund
The Gabelli SRI Fund, Inc.
The Gabelli Utilities Fund
The Gabelli Utility Trust
The Gabelli Value Fund Inc.

GABELLI CAPITAL SERIES FUNDS, INC.:
The Gabelli Capital Asset Fund

COMSTOCK FUNDS, INC.
Comstock Capital Value Fund

Comstock Strategy Fund

GABELLI EQUITY SERIES FUNDS, INC.:
The Gabelli Equity Income Fund

The Gabelli Small Cap Growth Fund The Gabelli Woodland Small Cap Value Fund

GAMCO GLOBAL SERIES FUNDS, INC.:

The GAMCO Global Telecommunications Fund The GAMCO Global Convertible Securities Fund The GAMCO Global Growth Fund
The GAMCO Global Opportunity Fund

GABELLI INVESTOR FUNDS, INC.:
The Gabelli ABC Fund

THE GABELLI MONEY MARKET FUNDS:
The Gabelli U.S. Treasury Money Market Fund

THE WESTWOOD FUNDS:

Westwood Equity Fund
Westwood Intermediate Bond Fund Westwood Balanced Fund
Westwood SmallCap Equity Fund Westwood Income Fund
Westwood Mighty Mites Fund

May 15, 2007

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