SecProbe.io

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                                   Foxby Corp.
                            Global Income Fund, Inc.
                               11 Hanover Square
                               New York, NY 10005

August 24, 2007

Larry  L. Greene, Esq.
Division of Investment Management
Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Re:  Comments on Preliminary Proxy Statements of Global Income Fund, Inc. (SEC
     File Nos. 333-111045 and 811-08025) and Foxby Corp. (SEC File Nos.
     333-74407 and 811-09261) filed on July 20, 2007

Dear Mr. Greene:

         On behalf of Global Income Fund, Inc. ("Global") and Foxby Corp. (each
a "Registrant" and together, the "Registrants"), set forth below are the
comments that you provided by telephone on July 26, 2007 to Yoon Choo of
Kirkpatrick & Lockhart Preston Gates Ellis LLP concerning the above-referenced
preliminary proxy statements (each a "Proxy Statement" and together, the "Proxy
Statements"). Your comment relating to the reconciliation of Section 18(i) of
the Investment Company Act of 1940, as amended (the "1940 Act") and the Maryland
Control Share Acquisition Act was addressed in our letter dated August 2, 2007.
Your comments are set forth in italics and are followed by the Registrants'
responses. Defined terms used but not defined herein have the meanings ascribed
to them in the Proxy Statements.

1.       COMMENT: FOR TEXT THAT APPEARS AS "ALL CAPS" IN THE PROXY STATEMENTS
         ANOTHER MEANS SHOULD USE BE USED TO HIGHLIGHT THEIR IMPORTANCE.

         Response: Certain text appears as "ALL CAPS" in the Proxy Statements as
filed with the Securities and Exchange Commission ("SEC") because the ASCII
program used to prepare the filing cannot otherwise denote bold or italicized
text. The print versions of the definitive proxy statements that will be mailed
to shareholders will utilize bold and/or italics to set off such language.

2.       COMMENT: UNDER "VOTE REQUIRED" ON PAGE 2 OF EACH PROXY STATEMENT,
         PLEASE EXPLAIN THE SIGNIFICANCE OF A PLURALITY VOTING STANDARD IN THE
         ELECTION OF THE NOMINEE.

         Response: As requested, a statement has been inserted explaining the
plurality voting standard. Please see page 2 of each definitive proxy statement.

3.       COMMENT: THE FOLLOWING STATEMENT APPEARS IN THE LAST PARAGRAPH UNDER
         THE HEADING "THE PROPOSED AGREEMENT" OF EACH PROXY STATEMENT: "[T]HE
         INVESTMENT MANAGER MAY ALSO ALLOCATE PORTFOLIO TRANSACTIONS TO
         BROKER/DEALERS THAT REMIT A PORTION OF THEIR COMMISSIONS AS A CREDIT
         AGAINST FUND EXPENSES." PLEASE EXPLAIN SUPPLEMENTALLY WHO IS REMITTING
         THESE COMMISSIONS AND WHAT PORTION OF THESE COMMISSIONS IS BEING
         REMITTED AS A CREDIT AGAINST FUND EXPENSES.

         Response: Each Registrant may enter into commission recapture programs,
which enable it to pay some of its operational expenses by recouping a portion
of the commissions it pays to a broker/dealer that is not a related party of the
Registrant. Any such arrangement would benefit the Registrant and not the
Registrant's service providers. The Registrants do not currently have any such
arrangements in place but may enter into such programs in the future.

4.       COMMENT: THE FOLLOWING STATEMENT APPEARS IN THE LAST PARAGRAPH UNDER
         THE HEADING "THE PROPOSED AGREEMENT" OF EACH PROXY STATEMENT: "[T]O THE
         EXTENT ANY SUCH BROKERAGE OR RESEARCH SERVICES MAY BE DEEMED TO BE
         ADDITIONAL COMPENSATION TO THE INVESTMENT MANAGER FROM THE FUND, IT IS
         AUTHORIZED BY THE PROPOSED AGREEMENT." PLEASE EXPLAIN SUPPLEMENTALLY
         THE LEGAL BASIS FOR TAKING THIS POSITION. IF YOU ARE AWARE OF ANY
         PRECEDENT FOR THIS POLICY, PLEASE LET US KNOW.

         Response: This disclosure is intended simply to reflect the fact that
research received by the Investment Manager through soft dollar arrangements
could benefit the Investment Manager and thus could be characterized as
additional compensation to the Investment Manager. Such soft dollar arrangements
are entered into in accordance with Section 28(e) of the Securities Exchange Act
of 1934, as amended.

5.       COMMENT: UNDER THE HEADING "DIFFERENCES BETWEEN THE CURRENT AND
         PROPOSED AGREEMENTS" OF EACH PROXY STATEMENT, THERE IS A STATEMENT THAT
         THE PROPOSED AGREEMENT CONTAINS A CONFIDENTIALITY CLAUSE. PLEASE
         EXPLAIN SUPPLEMENTALLY WHO IS BOUND BY THE CONFIDENTIALITY CLAUSE AND
         THE SCOPE OF THE CONFIDENTIALITY PROVISION.

         Response: Section 5 of each Proposed Agreement provides that "[t]he
Investment Manager shall keep confidential any information obtained in
connection with its duties" under the agreement. Such confidentiality would
apply under all circumstances except where the Registrant has authorized or
directed certain disclosure or if such disclosure is expressly required or
lawfully requested by applicable federal or state regulatory authorities.

6.       COMMENT: UNDER THE HEADING "DIFFERENCES BETWEEN THE CURRENT AND
         PROPOSED AGREEMENTS" OF EACH PROXY STATEMENT, THERE IS A STATEMENT THAT
         UNDER EACH PROPOSED AGREEMENT "[T]HE INVESTMENT MANAGER SHALL NOT BE
         LIABLE FOR DELAYS OR ERRORS OCCURRING BY REASON OF CIRCUMSTANCES BEYOND
         ITS CONTROL." PLEASE EXPLAIN SUPPLEMENTALLY WHAT TYPES OF DELAYS OR
         ERRORS ARE CONTEMPLATED BY THIS CLAUSE AND CONFIRM THAT THE INVESTMENT
         MANAGER WOULD NONETHELESS BE LIABLE FOR DELAYS AND ERRORS THAT ARE
         CAUSED BY ACTIONS OF THE INVESTMENT MANAGER THAT WOULD AMOUNT TO
         DISABLING CONDUCT UNDER SECTION 17(I) OF THE 1940 ACT.

         Response: Section 11 of each Proposed Agreement provides examples of
circumstances beyond the Investment Manager's control for which the Investment
Manager would not be liable for delays or errors "including but not limited to
acts of civil or military authority, national emergencies, work stoppages, fire,
flood, catastrophe, acts of god, insurrection, war, riot, or failure of
communication or power supply. In the event of equipment breakdowns beyond its
control, the Investment Manager shall take reasonable steps to minimize service
interruptions but shall have no liability with respect thereto." Irrespective of
the foregoing, the Investment Manager would still be liable for losses suffered
by a Registrant or its shareholders caused by actions of the Investment Manager
that would amount to disabling conduct under Section 17(i) of the 1940 Act.

7.        COMMENT: THE FOLLOWING SENTENCE APPEARS UNDER THE HEADING "DIFFERENCES
          BETWEEN THE CURRENT AND PROPOSED AGREEMENTS" OF EACH PROXY STATEMENT:
          "[T]HE PROPOSED AGREEMENT CONTAINS A CONFIDENTIALITY CLAUSE AND
          PROVIDES FOR REIMBURSEMENT OF EXPENSES, INCLUDING THE FEES AND
          EXPENSES OF THE INVESTMENT MANAGER'S LEGAL COUNSEL, BY THE FUND IN
          CONNECTION WITH DISCLOSURE OF CONFIDENTIAL INFORMATION, EXPRESSLY
          REQUIRED OR LAWFULLY REQUESTED BY APPLICABLE FEDERAL OR STATE
          REGULATORY AUTHORITIES OR OTHERWISE." THAT STATEMENT IS FOLLOWED BY A
          STATEMENT THAT "[T]HE CURRENT AGREEMENT DOES NOT CONTAIN A SIMILAR
          PROVISION." PLEASE CLARIFY WHETHER THE STATEMENT REFERS ONLY TO THE
          IMMEDIATELY PRECEDING CLAUSE (REGARDING REIMBURSEMENT OF THE
          INVESTMENT MANAGER FOR EXPENSES INCURRED IN CONNECTION WITH DISCLOSURE
          OF CONFIDENTIAL INFORMATION TO FEDERAL OR STATE REGULATORY
          AUTHORITIES) OR THE ENTIRE SENTENCE PRECEDING SUCH STATEMENT IN THE
          PARAGRAPH.

         Response: The definitive proxy statements have been revised to clarify
that reference  is  being  made to the  entire  sentence.  Please  see page 4 of
each definitive proxy statement.

8.       COMMENT: UNDER THE HEADING "DIFFERENCES BETWEEN THE CURRENT AND
         PROPOSED AGREEMENTS" OF GLOBAL'S PROXY STATEMENT, YOU STATE THAT THE
         CURRENT AGREEMENT CONTAINS A PROVISION THAT THE INVESTMENT MANAGER WILL
         WAIVE ALL OR PART OF ITS FEE OR REIMBURSE THE FUND MONTHLY IF AND TO
         THE EXTENT THE AGGREGATE OPERATING EXPENSES OF THE FUND EXCEED THE MOST
         RESTRICTIVE LIMIT IMPOSED BY ANY STATE IN WHICH SHARES OF THE FUND ARE
         QUALIFIED FOR SALE. YOU ALSO STATE THAT THE PROPOSED AGREEMENT
         ELIMINATES THIS PROVISION. ARE THERE STATES IN WHICH THE REGISTRANTS'
         SHARES ARE QUALIFIED FOR SALE THAT CURRENTLY IMPOSE THESE LIMITATIONS?
         IS SO, PLEASE NOTE THIS FACT IN THE DEFINITIVE PROXY STATEMENTS.

         Response: No state currently imposes an aggregate operating expense
limitation that the Registrants are subject to.

9.       COMMENT: PLEASE EXPLAIN SUPPLEMENTALLY WHY THE GOVERNING LAW OF THE
         PROPOSED AGREEMENTS WAS CHANGED FROM NEW YORK TO MARYLAND. A RESPONSE
         IS NOT REQUIRED IF THERE ARE NO UNUSUAL REASONS FOR THE CHANGE.

         Response: The parties to the Proposed Agreement believe the governing
law of the Proposed Agreements should be Maryland because both Registrants are
Maryland corporations.

10.      COMMENT: IN THE FORM OF PROXY ATTACHED TO EACH PROXY STATEMENT, PLEASE
         INDICATE ON WHOSE BEHALF THE PROXIES ARE BEING SOLICITED. PLEASE
         PROVIDE A BRIEF DESCRIPTION OF THE PROPOSED AMENDMENTS TO EACH
         REGISTRANT'S CHARTER.

         Response: Revisions to the form of proxy have been made to reflect your
comments. Please see the revised form of proxy filed with each definitive proxy
statement.

         Each Registrant acknowledges that: (1) it is responsible for the
adequacy and accuracy of the disclosure in its Proxy Statement and the
definitive proxy statement; (2) staff comments or changes to disclosure in
response to staff comments in the Proxy Statement reviewed by the staff do not
foreclose the SEC from taking any action with respect to the definitive proxy
statement; and (3) it may not assert staff comments as a defense in any
proceeding initiated by the SEC or any person under the federal securities laws
of the United States.

                                      * * *

         Please contact R. Darrell Mounts at (202) 778-9298 or Yoon Choo at
(202) 778-9340 if you have any questions relating to these responses or if you
require any further information. Thank you for your attention to this matter.

                                                    Very truly yours,

                                                    /s/Thomas B. Winmill
                                                    ----------------------------
                                                    Thomas B. Winmill
                                                    President

cc:      R. Darrell Mounts

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