March 26, 2008


David Joire, Esq.
Willkie Farr & Gallagher LLP
1875 K Street, NW
Washington, DC  20006


      RE:	The Gabelli Global Multimedia Trust
      333-149414; 811-08476

Dear Mr. Joire:

	We have reviewed the registration statement on Form N-2 for
The
Gabelli Global Multimedia Trust, filed with the Securities and
Exchange Commission on February 27, 2008.  We have the following
comments:

PROSPECTUS

Prospectus Summary

1. The registration statement pertains to a shelf offering for
preferred stock but does not disclose the material terms of these
securities.  Please revise the disclosure to include the material
terms of the subject securities.

2. Under the heading, "Investment Objective and Policies," the
disclosure states that "[t]he Fund will invest at least 80% of the
value of its assets in common stocks and other securities...of
companies in the telecommunications, media, publishing, and
entertainment industries."  Please provide an asset and/or revenue
test for issues deemed to be in these industries (i.e., 50% of its
assets devoted to or 50% of its revenues derived from these
industries).

3. Under the heading, "Use of Proceeds," please disclose how long
it
will take the Fund to invest the proceeds from the offering.

4. Under the heading, "Special Risks for Holders of Variable Rate
Preferred Stock," the disclosure states that "[t]he Fund has
entered
into two interest rate swap transactions with respect to its
outstanding Series C Auction Rate Preferred...The use of interest
rate swaps and caps is a highly specialized activity that involves
certain risks to the Fund including, among others, counterparty
risk
and early termination risk."  Please provide additional
information
concerning the creditworthiness of the counterparties.

5. Under the heading "Repurchase of Common Stock," the disclosure
states that "[t]he Board has authorized the Fund to repurchase up
to
1,700,000 shares of its common stock on the open market when the
shares are trading at a discount of 10% or more...from net asset
value of the shares."  Please make it clear whether the Fund will
repurchase its common shares in the open market when the common
shares are trading at a discount of 10% or whether the Fund
reserves
the freedom of action to repurchase its common shares.

Investment Objectives and Policies

6. The disclosure states that "[u]nder normal circumstances, the
Fund
will invest in securities of issuers located in at least three
countries, which may include the United States."  It later states
that "[w]hile the Investment Adviser expects that a substantial
portion of the Fund`s portfolio may be invested in the securities
of
domestic companies, a significant portion of the Fund`s portfolio
may
also be comprised of the securities of issuers headquartered
outside
the United States."  Please revise the disclosure to clarify the
Fund`s commitment to invest "globally."

Regulatory Matters

7. The disclosure states, "In February 2007, the Investment
Adviser
made an offer of settlement to the Staff for communication to the
SEC
for its consideration to resolve this matter.  This offer of
settlement is subject to final agreement regarding the specific
language of the SEC`s administrative order and other settlement
documents.  Since these discussions are ongoing, the Investment
Adviser cannot determine whether they will ultimately result in a
settlement of this matter and, if so, what the terms of the
settlement might be."  Please update the disclosure as applicable
and
provide more specific information concerning the settlement offer.


STATEMENT OF ADDITIONAL INFORMATION

Investment Restrictions

8. The first restrictions states that the Fund may not "[i]nvest
25%
or more of its total assets, taken at market value at the time of
each investment, in the securities of issuers in any particular
industry other than the telecommunications, media, publishing and
entertainment industries."  Please restate the restriction to make
it
clear that the Fund will invest 25% or more of its total assets in
the telecommunications, media, publishing and entertainment
industries.


GENERAL

9. We note that portions of the filing are incomplete.  We may
have
additional comments on such portions when you complete them in a
pre-
effective amendment, on disclosures made in response to this
letter,
on information supplied supplementally, or on exhibits added in
any
pre-effective amendments.

10. If you intend to omit certain information from the form of
prospectus included with the registration statement that is
declared
effective in reliance on Rule 430A under the Securities Act,
please
identify the omitted information to us supplementally, preferable
before filing the Fund`s final pre-effective amendment.

11. Response to this letter should be in the form of a pre-
effective
amendment filed pursuant to Rule 472 of the Securities Act.  Where
no
change will be made in the filing in response to a comment, please
indicate this fact in a supplemental letter and briefly state the
basis for your position.


TANDY LETTER

   We urge all persons who are responsible for the accuracy and
adequacy of the disclosure in the filings reviewed by the staff to
be
certain that they have provided all information investors require
for
an informed decision.  Since the Fund and its management are in
possession of all facts relating to the Fund`s disclosure, they
are
responsible for the accuracy and adequacy of the disclosures they
have made.

   Notwithstanding our comments, please furnish a letter
acknowledging that
* Should the Commission or the staff, acting pursuant to delegated
authority, declare the filing effective, it does not foreclose the
Commission from taking any action with respect to the filing;
* The action of the Commission or the staff, acting pursuant to
delegated authority, in declaring the filing effective, does not
relieve the Fund from its full responsibility for the adequacy and
accuracy of the disclosure in the filing; and
* The Fund may not assert this action as defense in any proceeding
initiated by the Commission or any person under the federal
securities laws of the United States.

   In addition, please be advised that the Division of Enforcement
has access to all information you provide to the staff of the
Division of Investment Management in connection with our review of
your filing or in response to our comments on your filing.

   We will consider a written request for acceleration of the
effective date of the registration statement as a confirmation of
the
fact that those requesting acceleration are aware of their
respective
responsibilities.  We will act on the request and, pursuant to
delegated authority, grant acceleration of the effective date.


			*		*		*		*
     If you have any questions about these comments, please call
me
at 202-551-6957.

								Sincerely,



								Laura E. Hatch
								Staff Accountant