mye_precltr103.htm

0000807249-10-000112.txt : 20120816 0000807249-10-000112.hdr.sgml : 20120816 20100408165000 ACCESSION NUMBER: 0000807249-10-000112 CONFORMED SUBMISSION TYPE: CORRESP PUBLIC DOCUMENT COUNT: 1 FILED AS OF DATE: 20100408 FILER: COMPANY DATA: COMPANY CONFORMED NAME: GAMCO Asset Management Inc. CENTRAL INDEX KEY: 0001460612 IRS NUMBER: 134044521 STATE OF INCORPORATION: NY FISCAL YEAR END: 1231 FILING VALUES: FORM TYPE: CORRESP BUSINESS ADDRESS: STREET 1: ONE CORPORATE CENTER CITY: RYE STATE: NY ZIP: 10580 BUSINESS PHONE: 914-921-5000 MAIL ADDRESS: STREET 1: ONE CORPORATE CENTER CITY: RYE STATE: NY ZIP: 10580 CORRESP 1 filename1.htm mye_precltr103.htm

One Corporate Center GAMCO Asset Management Inc.

Rye, NY 10580-1435-1422

Tel. (914) 921-7732

Fax (914) 921-5384

pgoldstein@gabelli.com

April 8, 2010

Peggy Kim, Esq.

Special Counsel

Office of Mergers & Acquisitions

U.S. Securities and Exchange Commission

100 F. Street, N.E.

Washington, D.C. 20549

Re: Myers Industries, Inc.

Preliminary Proxy Statement on Schedule 14A

Filed March 9, 2010 by GAMCO Asset Management Inc.

File No. 1-08524

Dear Ms. Kim:

GAMCO Asset Management Inc. (“GAMCO”) responds to your comment letter, dated April 7, 2010, concerning the Preliminary Proxy Statement filed by GAMCO and referenced above. We are responding to your comments as numbered in your letter. A revised preliminary proxy statement, as well as a red-lined version, reflecting changes from the earlier submission, are enclosed. GAMCO appreciates your timely and careful review of our submission.

1 .

In response to your comment, we have revised GAMCO’s proxy statement and proxy card to disclose that shareholders who grant GAMCO a proxy will be disenfranchised with respect to the six other director positions to be filled at the 2010 Annual Meeting. We also have revised the proxy statement to state that there is no assurance that the Myers’ nominees for election to the Board will serve if elected with any of GAMCO’s nominees.

We have revised the proxy statement to add detail concerning any plans the Nominees have for the Company in the Background to Solicitation section.

3.	We have revised the proxy card to identify each of the Participants.

Please contact me if you require additional information.

Sincerely,

GAMCO Asset Management Inc.

_/s/ Peter D. Goldstein_________

By: Peter D. GoldsteinDirector of Regulatory Affairs

Enclosures