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<TYPE>EX-99.77B ACCT LTTR
<SEQUENCE>2
<FILENAME>ggdeal77b.txt
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Report of Independent Registered Public Accounting Firm

To the Shareholders and Board of Trustees of
The Gabelli Global Deal Fund

In planning and performing our audit of the financial
statements of The Gabelli Global Deal Fund as of and for
the year ended December 31, 2009, in accordance with the
standards of the Public Company Accounting Oversight Board
(United States), we considered its internal control over
financial reporting, including control activities for
safeguarding securities, as a basis for designing our
auditing procedures for the purpose of expressing our
opinion on the financial statements and to comply with the
requirements of Form N-SAR, but not for the purpose of
expressing an opinion on the effectiveness of The Gabelli
Global Deal Fund's internal control over financial
reporting.  Accordingly, we express no such opinion.
The management of The Gabelli Global Deal Fund is
responsible for establishing and maintaining effective
internal control over financial reporting. In fulfilling
this responsibility, estimates and judgments by management
are required to assess the expected benefits and related
costs of controls. A company's internal control over
financial reporting is a process designed to provide
reasonable assurance regarding the reliability of financial
reporting and the preparation of financial statements for
external purposes in accordance with generally accepted
accounting principles. A company's internal control over
financial reporting includes those policies and procedures
that (1) pertain to the maintenance of records that, in
reasonable detail, accurately and fairly reflect the
transactions and dispositions of the assets of the company;
(2) provide reasonable assurance that transactions are
recorded as necessary to permit preparation of financial
statements in accordance with generally accepted accounting
principles, and that receipts and expenditures of the
company are being made only in accordance with
authorizations of management and directors of the company;
and (3) provide reasonable assurance regarding prevention
or timely detection of unauthorized acquisition, use or
disposition of a company's assets that could have a
material effect on the financial statements.
Because of its inherent limitations, internal control over
financial reporting may not prevent or detect
misstatements. Also, projections of any evaluation of
effectiveness to future periods are subject to the risk
that controls may become inadequate because of changes in
conditions, or that the degree of compliance with the
policies or procedures may deteriorate.
A deficiency in internal control over financial reporting
exists when the design or operation of a control does not
allow management or employees, in the normal course of
performing their assigned functions, to prevent or detect
misstatements on a timely basis. A material weakness is a
deficiency, or a combination of deficiencies, in internal
control over financial reporting, such that there is a
reasonable possibility that a material misstatement of the
company's annual or interim financial statements will not
be prevented or detected on a timely basis.
Our consideration of The Gabelli Global Deal Fund's
internal control over financial reporting was for the
limited purpose described in the first paragraph and would
not necessarily disclose all deficiencies in internal
control that might be material weaknesses under standards
established by the Public Company Accounting Oversight
Board (United States). However, we noted no deficiencies in
The Gabelli Global Deal Fund's internal control over
financial reporting and its operation, including controls
for safeguarding securities, that we consider to be a
material weakness as defined above as of December 31, 2009.

This report is intended solely for the information and use
of management and the Board of Trustees of The Gabelli
Global Deal Fund and the Securities and Exchange Commission
and is not intended to be and should not be used by anyone
other than these specified parties.


/s/ERNST & YOUNG LLP
February 25, 2010




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