MERRILL LYNCH GLOBAL GROWTH FUND, INC.
                             800 Scudders Mill Road
                          Plainsboro, New Jersey 08536

                                December 20, 2004


VIA ELECTRONIC FILING
Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C.  20549
Attention: Division of Investment Management

     Re:  Merrill Lynch Global Growth Fund, Inc.
          Post Effective Amendment No. 9 to Registration Statement on Form N-1A
          (File Nos.: 333-32899, 811-08327)
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Ladies and Gentlemen:

     We hereby request that the effective date for the above-captioned
Registration Statement be accelerated so that it will be declared effective at
10:00 a.m. on Tuesday, December 28, 2004, or as soon thereafter as practicable
after the filing of Post-Effective Amendment No. 9 with the Securities and
Exchange Commission (the "Commission").

     We hereby acknowledge that:

1.   Should the Commission, or the staff of the Commission (the "Staff") acting
     pursuant to delegated authority, declare this filing effective, it does not
     foreclose the Commission from taking any action with regard to the filing;

2.   The action of the Commission, or the Staff acting pursuant to delegated
     authority, in declaring the Fund effective, does not relieve the Fund from
     its responsibility for the adequacy and accuracy of the disclosure in this
     filing; and

3.   The Fund may not assert this action as a defense in any proceeding
     initiated by the Commission or any person under the Federal securities laws
     of the United States.

                                          Very truly yours,


                                          MERRILL LYNCH GLOBAL GROWTH FUND, INC.


                                          By:
                                              ----------------------------------
                                              Name:  Alice A. Pellegrino
                                              Title: Secretary


                                          FAM DISTRIBUTORS, INC.


                                          By:
                                              ----------------------------------
                                              Name:  Donald C. Burke
                                              Title: Vice President