Correspondence 0001999371-24-004811 from GABELLI MULTIMEDIA TRUST INC. (GGT, GGT-PE, GGT-PG) (CIK 0000921671) (GGT)
GABELLI MULTIMEDIA TRUST INC. (GGT, GGT-PE, GGT-PG) (CIK 0000921671)
Date: April 15, 2024 · CIK: 0000921671 · Accession: 0001999371-24-004811
AI Filing Summary & Sentiment
File numbers found in text: 333-277213, 811-08476
Letter
VIA EDGAR Division of Investment Management 100 F Street N.E. Washington, DC 20549 RE: The Gabelli Multimedia Trust Inc. (File Nos.: 333-277213; 811-08476)
Dear Mr. Foor:
Thank you for your oral comments provided on March 25, 2024, regarding your review of the registration statement on Form N-2 filed on February 21, 2024 (the “Registration Statement”) by The Gabelli Multimedia Trust Inc. (the “Fund”) with the U.S. Securities and Exchange Commission (the “SEC”). The Fund has considered your comments and authorized us to respond on its behalf as set forth below. Changes to the Registration Statement will be reflected in Pre-Effective Amendment No. 1 to the Registration Statement, which the Fund intends to file on or about the date hereof, and will be marked to show all changes made since the initial filing of the Registration Statement.
Your oral comments are summarized in bold to the best of our understanding, followed by the Fund’s responses. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement.
Jeff Foor
April 15, 2024
Page 2
***
Dividends and Distributions
1. Please inform the SEC’s staff (the “Staff”) whether the Fund intends to report a distribution rate. If the Fund does intend to report a distribution rate at any point prior to finalizing tax figures, the Staff notes that the Fund should disclose the estimated portion of the distribution rate that results from a return of capital. The Staff requests that any reports that would contain a distribution yield needs to be accompanied by the full return and/or SEC yield.
The Fund confirms that it will follow applicable SEC and Staff guidance to the extent that it reports a distribution rate.
* * * * * * *
Should you have any additional comments or concerns, please do not hesitate to contact me at (617) 573-4836.
Best regards,
/s/ Kenneth E. Burdon
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Skadden,
Arps, Slate, Meagher & Flom llp
500 BOYLSTON STREET
Boston, Massachusetts 02116
TEL:
(617) 573-4800
FAX:
(617) 573-4822
www.skadden.com
DIRECT DIAL
(617)
573-4836
DIRECT
FAX
(617)
305-4836
EMAIL
ADDRESS
KENNETH.BURDON@SKADDEN.COM
FIRM/AFFILIATE
OFFICES
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CHICAGO
HOUSTON
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NEW
YORK
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WASHINGTON,
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KONG
LONDON
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SHANGHAI
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TOKYO
TORONTO
April 15, 2024
VIA EDGAR
Jeff Foor
Division of Investment Management
U.S. Securities and Exchange Commission
100 F Street N.E.
Washington, DC 20549
RE: The Gabelli Multimedia Trust Inc.
(File Nos.: 333-277213; 811-08476)
Dear Mr. Foor:
Thank you for your oral comments
provided on March 25, 2024, regarding your review of the registration statement on Form N-2 filed on February 21, 2024 (the “Registration
Statement”) by The Gabelli Multimedia Trust Inc. (the “Fund”) with the U.S. Securities and Exchange Commission
(the “SEC”). The Fund has considered your comments and authorized us to respond on its behalf as set forth below. Changes
to the Registration Statement will be reflected in Pre-Effective Amendment No. 1 to the Registration Statement, which the Fund intends
to file on or about the date hereof, and will be marked to show all changes made since the initial filing of the Registration Statement.
Your oral comments are summarized
in bold to the best of our understanding, followed by the Fund’s responses. Capitalized terms not otherwise defined herein have
the meanings ascribed to them in the Registration Statement.
Jeff Foor
April 15, 2024
Page 2
***
Dividends and Distributions
1. Please inform the SEC’s staff (the “Staff”) whether the Fund intends to report
a distribution rate. If the Fund does intend to report a distribution rate at any point prior to finalizing tax figures, the Staff notes
that the Fund should disclose the estimated portion of the distribution rate that results from a return of capital. The Staff requests
that any reports that would contain a distribution yield needs to be accompanied by the full return and/or SEC yield.
The Fund confirms
that it will follow applicable SEC and Staff guidance to the extent that it reports a distribution rate.
* * * * * * *
Should you have any additional comments or concerns,
please do not hesitate to contact me at (617) 573-4836.
Best regards,
/s/ Kenneth E. Burdon
Kenneth E. Burdon