April 28, 2010

Ms. Laura E. Hatch
United States Securities and Exchange Commission
Division of Investment Management
100 F Street, N.E.
Washington, DC 20549

Re:      The Gabelli Asset Fund (the "Fund")
         Post-Effective Amendment No. 29 to the Registration Statement
         on Form N-1A (33-01719)

Dear. Ms. Hatch:

         This letter  responds to your  comments  communicated  by  telephone on
April 7,  2010,  with  respect  to the  Post-Effective  Amendment  No. 29 to the
Registration  Statement on Form N-1A (the "Registration  Statement") of the Fund
that was filed  with the  Securities  and  Exchange  Commission  (the  "SEC") on
February 26, 2010 (accession number 0000950123-10-017784).

         In addition, in connection with this filing, the Fund hereby states the
following:

         1.       The Fund  acknowledges  that in  connection  with the comments
                  made by the Staff of the SEC,  the Staff has not passed on the
                  accuracy or adequacy of the  disclosure  made herein,  and the
                  Fund and its management are solely responsible for the content
                  of such disclosure;

         2.       The Fund acknowledges  that the Staff's comments,  and changes
                  in  disclosure  in response to the  Staff's  comments,  do not
                  foreclose   the  SEC  or  other   regulatory   body  from  the
                  opportunity  to seek  enforcement  or take other  action  with
                  respect to the disclosure made herein; and

         3.       The Fund  represents  that neither it nor its management  will
                  assert  the  Staff's  comments  or changes  in  disclosure  in
                  response to the Staff's comments as a defense in any action or
                  proceeding by the SEC or any person.

                  The Fund's  responses to your  comments are  reflected  below.
         Comments that applied to both the Class AAA Shares  prospectus  and the
         Class  ABCI  Shares  prospectus  have only  been  addressed  once.  The
         substance  of  your  comments  has  been  restated  for  your  ease  of
         reference.



         COMMENT  #1-COVER  PAGE:  You  requested  that the Fund  pare  down the
         information  in  the  top  left  hand  corner  to  remove   duplicative
         references.

                  RESPONSE #1: The Fund has deleted the following parenthetical
                  language that appears at the end of the disclosure in the top
                  left hand corner: "(Net Asset Value per share may be obtained
                  daily by calling 800-GABELLI after 7:00 p.m.)."

         COMMENT  #2-COVER  PAGE:  You requested  that the Fund add the required
         legend disclosure if we intend to utilize a summary prospectus.

                  RESPONSE  #2:  The  Fund  will  not  be  utilizing  a  summary
                  prospectus  at this time and therefore the legend has not been
                  added.

         COMMENT #3-PRINCIPAL INVESTMENT STRATEGIES: In the first paragraph, you
         made  reference  to the  Fund's  investing  in  securities  that may be
         converted  into common  stock.  If the Fund does not hold a significant
         portion of its  portfolio  in  securities  that may be  converted  into
         common stock, you requested that we move the disclosure to "Information
         About the Fund's  Investment  Objectives,  Investment  Strategies,  and
         Related Risks" and to include  disclosure  regarding the credit quality
         and risks of investing in convertible securities.

                  RESPONSE #3: The Fund does not invest a significant portion of
                  its portfolio in  convertible  securities;  consequently,  the
                  Fund  has  removed  the  following  language  from  the  first
                  paragraph of the "Principal  Investment  Strategies"  section:
                  "and may also invest in securities  that may be converted into
                  common stocks."

                  As a  conforming  change,  the Fund also has revised the first
                  sentence  of  the  third   paragraph   under  the   "Principal
                  Investment Strategies" to read:

                  "The Fund's assets will be invested primarily in a broad range
                  of readily  marketable equity securities  consisting of common
                  stock and preferred stock."

                  The Fund has also added the following under  "Investing in the
                  Fund involves the following risks:":

                  o CONVERTIBLE  SECURITIES AND CREDIT RISK. The characteristics
                  of convertible  securities make them  appropriate  investments
                  for  investors  who seek a high level of total return with the
                  addition of credit  risk.  These  characteristics  include the
                  potential  for  capital  appreciation  if  the  value  of  the
                  underlying  common stock increases,  the relatively high yield
                  received  from  dividend or  interest  payments as compared to
                  common  stock  dividends,  and  decreased  risks of decline in
                  value, relative to the


                  underlying common stock due to their fixed income nature. As a
                  result of the conversion feature,  however,  the interest rate
                  or dividend preference on a convertible  security is generally
                  less  than  would  be the  case  if the  securities  were  not
                  convertible.  During  periods of rising  interest  rates,  the
                  potential for capital gain on a convertible  security might be
                  less than that of a common  stock  equivalent  if the yield on
                  the convertible  security is at a level that causes it to sell
                  at a  discount.  Any  common  stock or other  equity  security
                  received by conversion will not be included in the calculation
                  of the  percentage  of total  assets  invested in  convertible
                  securities.

         COMMENT  #4-PERFORMANCE  TABLE:  You requested that the Fund delete the
         second  sentence in the  paragraph  that  discusses  after-tax  returns
         regarding "Return After Taxes on Distributions and Sale of Fund Shares"
         if it is not applicable for the Fund.

                  RESPONSE  #4:This  disclosure  has  been  deleted,  as  it  is
                  inapplicable to Fund.

         COMMENT  #5-STATEMENT OF ADDITIONAL  INFORMATION ("SAI"): You requested
         that the Fund  include the new  corporate  governance  and board member
         disclosure.

                  RESPONSE #5: The Fund will include such disclosure in the SAI.

         Should you have any questions  regarding the  foregoing,  please do not
         hesitate  to  contact  Helen  A.  Robichaud  at PNC  Global  Investment
         Servicing, Inc., the Fund's Sub-Administrator, at 617-338-4595.

         Very truly yours,

         /s/ Bruce N. Alpert
         -------------------
         Bruce N. Alpert
         President

         cc:  Helen A. Robichaud        Arlene Lonergan
              PNC Global Investment     PNC Global Investment
              Servicing, Inc.           Servicing, Inc.

              Peter D. Goldstein        Richard Prins
              Gabelli Funds, LLC        Skadden, Arps, Slate, Meagher & Flom LLP

              Leslie Lowenbraun
              Skadden, Arps, Slate, Meagher & Flom LLP