SecProbe.io

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THOMPSON
HINE

   ATLANTA     BRUSSELS     CINCINNATI     CLEVELAND     COLUMBUS      DAYTON
                         NEW YORK   WASHINGTON, D.C.
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Submitted electronically

April 29, 2005

Vince DiStefano
U.S. Securities & Exchange Commission
Division of Investment Management
450 Fifth Street, N.W.
Washington, DC  20549
RE: Gateway Trust, File No. 2-59895 and 811-02773

Dear Mr. DiStefano:

On February 25, 2005, Gateway Trust (the "Trust") filed Post-Effective Amendment
No. 41 to its Registration Statement on Form N-1A. Please find below the Trust's
responses to your comments provided by telephone. For your convenience, I have
restated your comments.

Prospectus

         Comment: Under the heading "Purchasing Stocks," revise the disclosure
         to comply with plain English requirements.

         Response: The disclosure has been revised as requested, and the
         revisions are highlighted below.

         The Fund invests in a diversified stock portfolio designed to support
         the Fund's index-option-based risk management strategy as efficiently
         as possible while seeking to enhance the Fund's total return. The
         Adviser uses a multi-factor quantitative model to construct the stock
         portfolio. The model evaluates approximately 9,000 stocks traded on the
         New York Stock Exchange, the American Stock Exchange and the NASDAQ
         Stock Market to construct a portfolio that meets criteria and
         constraints established by the Adviser. Generally, the Adviser tries to
         minimize the difference between the performance of the stock portfolio
         and that of the index or indexes underlying the Fund's option strategy
         while also considering other factors, such as predicted dividend yield.
         The Adviser monitors this difference and the other factors, and
         rebalances and adjusts the stock portfolio from time to time. The
         portfolio is expected to be generally representative of the broad U.S.
         equity market.

Don.Mendelsohn@ThompsonHine.com     Phone 513.352.6546     Fax 513.241.4771

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April 29, 2005
Page 2

Statement of Additional Information

         Comment: With respect to the second paragraph of the section titled
         "Disclosure of Portfolio Holdings," explain supplementally whether the
         Board of Trustees considered the "conditions of confidentiality"
         identified as items (ii), (iii) and (iv) to be sufficient.

         Response: The Board of Trustees did consider whether these measures
         were sufficient and concluded that, due to the nature of the Fund and
         its portfolio holdings, the risk of misuse of portfolio information was
         very limited and, therefore, these measures are sufficient.

General

         Comment: Please provide a statement in response to the generic "Tandy"
         letter.

         Response: The Trust hereby acknowledges that:

         (a)      The Trust is responsible for the adequacy and accuracy of the
                  disclosure in the filings reviewed by the staff of the
                  Securities and Exchange Commission (the "Staff");

         (b)      Staff comments or changes to disclosure in response to Staff
                  comments in a filing reviewed by the Staff do not foreclose
                  the Commission from taking any action with respect to the
                  filing; and

         (c)      The Trust may not assert Staff comments as a defense in any
                  proceeding initiated by the Commission or any person under the
                  federal securities laws of the United States.

If you have any further questions or additional comments, please contact the
undersigned at 513-352-6546.

Very truly yours,

/s/ Donald S. Mendelsohn

Donald S. Mendelsohn

cc:      Donna Squeri

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