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  GAM Funds SEC Correspondence as filed April 27, 2005

[SRSY LOGO]                                  Stradley Ronon Stevens & Young, LLP
                                                            1220 19th Street, NW
                                                                       Suite 600
                                                           Washington, DC  20036
                                                       Telephone  (202) 822-9611
                                                              Fax (202) 822-0140

                                 April 27, 2005

VIA Edgar

Christian T. Sandoe, Esq.
Division of Investment Management
U.S. Securities and Exchange Commission
450 Fifth Street, N.W.
Washington, D.C. 20549

          Re:  GAM Funds,  Inc.  (File Nos.  2-92136 and 811-4062) - Response to
               SEC Comments on Post-Effective Amendment No. 42

Dear Mr. Sandoe:

We are responding to your comments,  provided, on your behalf by Chad Eskildsen,
via  telephone  on April  11,  2005 to  Post-Effective  Amendment  No. 42 to the
Registration  Statement of GAM Funds, Inc. (the "Registrant")  filed on February
25, 2005. Set forth below, we have briefly  summarized each of your comments and
our response  follows  immediately  thereafter.  Please note that we  previously
filed on April 22, 2005 a letter responding to your comments.  However,  we have
since decided to revise  certain  disclosures in the  Registrant's  Registration
Statement  and as a result,  are filing this revised  letter  responding to your
comments.

In connection with our responses to your comments, we acknowledge,  on behalf of
the Registrant, that:

o    The  Registrant  is  responsible  for  the  adequacy  and  accuracy  of the
     disclosure in the filing;
o    Staff  comments or changes to disclosure  in response to staff  comments in
     the filing  reviewed  by the staff do not  foreclose  the  Commission  from
     taking any action with respect to the filing; and
o    The Registrant 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.

General Comment

1.   Pursuant  to  SEC  Press  Release  2004-89  (June  24,  2004),   all  EDGAR
     correspondence  should  include  a "Tandy  letter"  that  includes  certain
     acknowledgements.

     Response:  The acknowledgements  required in a Tandy letter are included as
     the second paragraph of this response letter.

Prospectus Comments

2.   GAM International  Equity indicates that it will invest in stocks issued in
     at least three different  countries.  Please address how this complies with
     footnote 42 of the Names Rule Release.

     Response:  Footnote 42 of the Names Rule  Release  notes that the SEC staff
     expects  that a fund that uses the term  "International"  in its name would
     invest its assets in investments that are tied  economically to a number of
     countries  throughout  the world.  However,  the footnote  does not provide
     insight into what  constitutes  "a number of different  countries" nor does
     there  appear to be any other  interpretations  on this issue  other than a
     Staff issued Generic  Comment Letter (pub.  avail.  Jan. 3, 1991).  In that
     Generic Comment Letter,  the Staff  indicated that "an  international  fund
     should  have a policy  requiring  investment  in at least  three  different
     countries outside the United States." GAM International  Equity's principal
     investment strategy was drafted in reliance on that Generic Comment Letter.
     Furthermore,  footnote 43 to the Names Rule  Release  notes with respect to
     funds  that are not  subject  to the  Names  Rule  (Rule  35d-1  under  the
     Investment  Company  Act of 1940) that "an  investment  company may use any
     reasonable  definition  of the terms used in its name and should define the
     terms  used  in its  name  in  discussing  its  investment  objectives  and
     strategies in the prospectus." We believe that we have accomplished this by
     explicitly indicating that GAM International Equity will invest in at least
     three  countries  other than the United  States.  Finally,  as a  practical
     matter,  it is important to note that the Fund is generally  invested in at
     least ten countries at any given time.

3.   Since  Small/Mid-Cap  Risk is  listed as a  principal  risk for each of GAM
     European Equity,  GAM  Asia-Pacific  Equity and GAM  International  Equity,
     disclosure  regarding  small and mid-cap  investing  should be added to the
     "Principal Investment Strategy" section.

     Response:  The risk disclosure related to Small/Mid-Cap Risk has been moved
     to the Non-Principal Risks section because small/mid-cap investing is not a
     principal strategy for any of these Funds.

4.   Since  "Focus  Investing"  is  listed as a  principal  risk for each of GAM
     European Equity,  GAM  Asia-Pacific  Equity and GAM  International  Equity,
     disclosure  regarding  investing in a limited  number of issuers  should be
     added to the "Principal Investment Strategy" section.

     Response:  In  response  to your  comments,  we have  added  the  following
     sentences  to the  principal  investment  strategy for each of the affected
     funds:

     For GAM International Equity: "Typically, the Fund will invest in 60 to 100
     securities, which are mainly equities."

     For GAM Asia-Pacific Equity:  "Typically,  the Fund will invest in 50 to 70
     securities, which are mainly equities."

     For "GAM  European  Equity:  "Typically,  the Fund will invest in 80 to 120
     securities, which are mainly equities."

     Please note that the Focus  Investing  Risk  description  for GAM  European
     Equity  has been  revised  slightly  to  indicate  that the Fund  typically
     invests in less than 120 securities instead of 100.

5.   For all fee tables,  you have requested  that the lines  entitled  "Maximum
     Front-End  Sales  Charge" and "Maximum  Deferred  Sales Charge" be indented
     under the line entitled "Maximum Sales Charge."

     Response:  The typeset  version of the  prospectus  will include the change
     referenced above in all fee tables.

6.   The fee waiver line in the fee table for GAM Asia-Pacific  Equity should be
     eliminated  if the prior  contractual  waiver will not be in effect for the
     upcoming fiscal year.

     Response:  There is no longer a contractual  fee waiver for this fund. As a
     result,  the fee waiver  line has been  eliminated  from the fee table.  In
     addition,  we have  replaced  the prior  footnote to the fee table with the
     following new language:

     "The Investment  Adviser has  voluntarily  agreed to waive a portion of its
     advisory fee in the amount of 0.10% per annum during fiscal year 2005. As a
     result of this voluntary fee waiver, the total fund operating expenses paid
     by Class A, Class B and Class C Shares are expected to be 2.87%,  3.72% and
     4.83%, respectively."

7.   Since  "Derivative  Instruments" risk is listed as a principal risk for GAM
     Gabelli   Long/Short,   disclosure   regarding   investing  in   derivative
     instruments should be added to the "Principal Investment Strategy" section.

     Response:  The risk disclosure  related to Derivative  Instruments Risk has
     been  moved  to  the  Non-Principal  Risks  section  because  investing  in
     derivative instruments is not a principal strategy for the fund.

8.   Please  add  dates  of  employment  for  the  various   portfolio   manager
     biographies in a manner that is sufficient to indicate at least five year's
     experience.

     Response:  We have revised each portfolio manager's biography to respond to
     the comment above.

9.   In the fifth  paragraph  under the  section  entitled  "Frequent/Short-Term
     Trading or Market  Timing",  please  indicate  whether  the use of the word
     "may" in the first  sentence  indicates that market timing may be permitted
     for transactions placed through a financial intermediary.

     Response:  The use of the word "may" is not meant to  indicate  that market
     timing would be permitted in such  circumstances.  Rather, the use of "may"
     is  intended  to address  the fact that a Fund  cannot  always  identify or
     reasonably detect excessive trading for transactions placed through omnibus
     accounts. However, in response to your comment, we have revised this entire
     paragraph  to clarify the Fund's  ability to detect  excessive  trading for
     transactions placed through  intermediaries.  The revised paragraph appears
     below.

     "Investors who place transactions  through the same financial  intermediary
     on an omnibus  account  basis may be deemed part of a group for the purpose
     of this  policy and their  orders may be  rejected in whole or in part by a
     Fund.  The Funds,  however,  cannot  always  identify  or detect  excessive
     trading  that  may be  facilitated  by  financial  intermediaries  or  made
     difficult  to  identify  through  the  use of  omnibus  accounts  by  those
     intermediaries  that transmit  purchase,  exchange and redemption orders to
     the Funds, and thus the Funds may have difficulty curtailing such activity.
     Transactions  accepted by your financial  intermediary  and determined by a
     Fund's  principal  underwriter  to constitute  market timing are not deemed
     accepted by a Fund and may be  cancelled  or revoked by the Fund within one
     business day of the Fund's determination that the transaction violates this
     policy.  Some  investors  own their  shares in the  Funds  through  omnibus
     accounts at a financial institution.  In such cases, the Funds may not know
     the identity of individual  beneficial owners of the Funds' shares, and may
     not be  able  to  charge  a  redemption  fee to  the  individuals  actually
     redeeming Fund shares. However, the Company reviews all trading activity on
     behalf of omnibus accounts.  If any abuses are suspected,  the Company will
     contact the  intermediary  to determine  whether the Funds' policy has been
     violated and if so, to take  appropriate  action to deter future  abuses of
     the policy. The Funds' ability to impose restrictions and deter abuses with
     respect to  accounts  traded  through  particular  intermediaries  may vary
     depending on the systems  capabilities,  applicable  contractual  and legal
     restrictions and cooperation of those intermediaries."

10.  In the fifth  paragraph  under the  section  entitled  "Frequent/Short-Term
     Trading or Market  Timing",  the  second  sentence  indicates  transactions
     accepted  by a financial  intermediary  that are  determined  by the Fund's
     principal  underwriter to constitute  market timing may be cancelled by the
     Fund. In what timeframe would the transaction be cancelled?

     Response: The transaction would be cancelled within one business day of the
     Fund's  determination  that the  transaction  violates  the  market  timing
     policy.  See the  revised  disclosure  for this  paragraph  included in the
     response to Question 9 above.

11.  You  indicate  that  the  second   paragraph  under  the  section  entitled
     "Redemption Fees" is confusing and should be clarified.

     Response: The paragraph has been revised and now reads as follows:

     "Redemption fees are not charged for transactions in the Funds if the Funds
     are held in an  account  being  managed  by GAM on a  discretionary  basis.
     Market  timing  activities  with respect to these  accounts are  prohibited
     unless the  activity  is part of an asset  allocation  adjustment  effected
     across applicable discretionary managed accounts."

12.  Explain  supplementally  why a 1% redemption fee is charged only on Class A
     Shares and not all classes of shares.

     Response:  A redemption  fee is not assessed on the other classes of shares
     because those classes currently charge a contingent deferred sales charge.

SAI Comments

13.  In the section entitled  "Disclosure of Portfolio  Holdings," you indicated
     that  the  disclosure  should  address  the  following:   (a)  whether  any
     compensation  is  received by the Fund for  release of  portfolio  holdings
     information;  (b) the Board's oversight role in ensuring that the policy is
     being  followed;  (c) the procedures  used to ensure that the disclosure of
     portfolio  holdings  information  is in the best interests of the Fund; (d)
     who is  authorized  to release  portfolio  holdings  information;  (e) list
     current ongoing  relationships to release portfolio  holdings  information:
     and (f) explain who in  "Compliance"  has authority to make decisions under
     the policy.

     Response:  The entire  section  has been  revised  to  address  all of your
     comments above. The revised section appears below.

     "The Board of Directors has adopted  policies and procedures  regarding the
     disclosure of portfolio  holdings  information  to protect the interests of
     Fund shareholders and to address potential conflicts of interest that could
     arise between the interests of Fund  shareholders  and the interests of the
     Investment  Advisers,  principal  underwriter or affiliated  persons of the
     Investment  Advisers or principal  underwriter.  The Funds'  overall policy
     with  respect  to the  release of  portfolio  holdings  is to release  such
     information consistent with applicable legal requirements and the fiduciary
     duties owed to shareholders.  Subject to the limited  exceptions  described
     below, the Funds will not make available to anyone  non-public  information
     with  respect  to  their  portfolio  holdings,   until  such  time  as  the
     information is made available to all shareholders or the general public.

     These policies and procedures also are applicable to the Funds'  respective
     Investment  Advisers and their agents.  Pursuant to the policy,  the Funds,
     their Investment Advisers and their agents are obligated to:

o    Act in the best interests of Fund shareholders by protecting non-public and
     potentially material portfolio holdings information;
o    Ensure that  portfolio  holdings  information  is not provided to a favored
     group of clients or potential clients; and
o    Adopt  such  safeguards  and  controls  governing  the  release  of  client
     information so that no client or group of clients is unfairly disadvantaged
     as a result of such release.

     Pursuant to this policy,  only the Funds' top 10 holdings are  disclosed in
     marketing and other material.  For certain Funds, the disclosure is limited
     to fewer than 10 holdings.  Any requests  for  departures  from this policy
     from clients, or from other third parties, must be authorized by either the
     Chief Compliance Officer or General Counsel. In certain jurisdictions it is
     prohibited  by law to  make  available  to  some  shareholders  the  Funds'
     underlying  portfolio  positions unless all  shareholders  receive the same
     information. Providing such information to selected recipients could assist
     a person or entity in late  trading of the  Funds'  shares or allow them to
     engage in other  detrimental  trading  techniques  such as front running or
     short selling of the portfolio securities in the Funds.

     There are general and other limited  exceptions to this prohibition.  Third
     parties  that  provide  services  to the  Funds,  such as  trade  execution
     measurement  and  reporting  systems,   personal   securities   transaction
     monitor