[PAUL, HASTINGS, JANOFSKY & WALKER LLP LETTERHEAD]
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(212) 318-6275
rachaelschwartz@paulhastings.com


December 19, 2008                                                    33428.00001


Securities and Exchange Commission
100 F Street, N.E.
Washington, DC   20549

Re:      The GAMCO Westwood Funds (the "Trust") (033-06790)

Ladies and Gentlemen:

Transmitted herewith for filing is a Registration Statement on Form N-14 for the
above  referenced  Trust, on behalf of the GAMCO Westwood Mighty MitesSM Fund, a
series  thereof (the Mighty Mites Fund").  As indicated on the facing page,  the
Trust  proposes that the filing become  effective on or before January 20, 2009,
pursuant to Rule 488(a)  under the  Securities  Act of 1933.  This  Registration
Statement is being filed in connection with the proposed  reorganization  of the
B.B.  Micro-Cap Growth Fund, a series of The B.B. Funds, into the Trust's Mighty
Mites Fund.

Please call the undersigned at (212) 318-6275 with any questions or comments you
may have regarding the filing. Thank you.

Very truly yours,

/s/ Rachael L. Schwartz

Rachael L. Schwartz
for PAUL, HASTINGS, JANOFSKY & WALKER LLP