November 17, 2005


Michael R. Anastasio, Jr.
Vice President and Chief Financial Officer
One Corporate Center
Rye, New York  10580-1422

      Re:	GAMCO Investors, Inc. (the "Registrant")

Dear Mr. Anastasio:

      The Division of Investment Management ("IM") has reviewed
your
response letter filed on September 29, 2005 and has the following
comments.

1.	Please indicate whether Gabelli Funds, LLC ("Gabelli") and
GAMCO
Asset Management Inc. ("GAMCO," and together with Gabelli, the
"subsidiaries") are investment companies under section 3(a) of the
Investment Company Act of 1940 (the "Investment Company Act").  If
you conclude that the subsidiaries are investment companies,
please
discuss how the subsidiaries` status as investment companies
affects
the Registrant`s status as an investment company.  Providing IM
with
a balance sheet for each subsidiary may facilitate its review.

2.	Please explain why an EBITDA multiple of 10 is appropriate
for
purposes of fair valuing the subsidiaries.

3.	Please indicate the number of individuals that manage and
administer the Registrant`s proprietary investments and whether
these
individuals are directors or executive officers.  Please also
clarify
how much time, on a percentage basis, these individuals devote to
managing and administering the proprietary investments in relation
to
other corporate matters.

* * * * *

      Please respond to these comments within 10 business days or
tell us when you will provide us with a response.  Detailed
letters
greatly facilitate our review.  You may submit your response to
these
comments in your response letter to the most recent comment letter
of
the Division of Corporation Finance (dated November 4, 2005).
Please
understand that IM may have additional comments after reviewing
your
responses to our comments.

	You may contact the undersigned at (202) 551-6858 if you have
any questions.  My mail stop is 0504.


						Sincerely,



						John L. Sullivan
						Senior Counsel