SecProbe.io

CORRESP
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December 14, 2023

VIA EDGAR

Mr. Kenneth Ellington

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Ms. Ashley Vroman-Lee

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

 Re: Response to additional Comments on the Proxy Statements/Prospectuses (each, a “Proxy Statement/Prospectus”
and collectively, the “Proxy Statements/Prospectuses”) and statements of additional information (each, an “SAI”
and collectively, the “SAIs”) filed on Form N-14 on October 24, 2023 and Pre-Effective Amendment No. 1 on Form N-14
on December 12, 2023 for the following funds (each, an “Acquiring Fund” or a “Registrant” and collectively,
the “Acquiring Funds” or the “Registrants”):

abrdn Total Dynamic Dividend Fund

Securities
Act File No. 333-275152

abrdn Global Infrastructure Income
Fund

Securities
Act File No. 333-275177

Mr. Ellington and Ms. Vroman-Lee:

This
letter responds to additional Comments on the Proxy Statements/Prospectuses and SAIs with respect to the proposed reorganizations as shown
below that the staff (the “Staff”) of the Securities and Exchange Commission (the “SEC”) provided via telephone
with Ashley Vroman-Lee and Kimberley Church of Dechert LLP on December 12, 2023 and via telephone with Anu Dubey and Kenneth
Ellington and Patricia Leeson of Dechert LLP on December 13, 2023.

    Acquired Funds (each, an “Acquired Fund”)

    Acquiring Funds

    First Trust Specialty Finance and Financial Opportunities Fund
    into
    abrdn Total Dynamic Dividend Fund

    Macquarie/First Trust Global Infrastructure/Utilities Dividend & Income Fund
    into
    abrdn Global Infrastructure Income Fund

Revised Proxy Statements/Prospectuses and SAIs
were filed on December 12, 2023 (“Pre-Effective Amendment No. 1”) in order to make certain changes in connection
with the Staff’s initial comments on the Proxy Statements/Prospectuses and SAIs. The Registrants previously responded to these initial
comments from Mr. Kenneth Ellington and Ms. Vroman-Lee in a letter dated December 12, 2023.

On behalf of the Acquiring Funds, your comments
and our responses thereto are provided below. All defined terms in this letter have the same meaning as in the Proxy Statements/Prospectuses
and SAIs, except as defined herein.

Comments provided on December 12, 2023

Comments applicable to each Proxy Statement/Prospectus

Comment
1: In the “Proposals—Background and Reasons for the Proposed Reorganization” section, it is disclosed
that “First Trust reviewed its evaluation of the strategic alternatives considered for the Acquired Fund, including maintaining
the status quo, liquidation, conversion to an open-end fund, reorganization with an affiliated fund and reorganization with a third-party
fund, and advised that, based on its evaluation, First Trust had determined that a reorganization with a third-party fund would be in
the overall best interests of the Acquired Fund.” Please revise the disclosure to explain why the Board determined that a reorganization
with a third-party fund would be in the best interests of the Acquired Fund, including why this was determined to be a better alternative
than the other options.

Response:
The Registrants respectfully submit that the “Proposal—Background and Reasons for the Proposed Reorganization” section
sets forth the reasons for the Board’s determination that each proposed Reorganization is in the overall best interests of the respective
Acquired Fund. The Registrants have revised the eleventh bullet in response to this comment as follows:

Alternatives
to the Reorganization. The Board noted First Trust’s consideration discussion of alternatives
to the Reorganization, including maintaining the status quo, liquidation, conversion to an open-end fund, reorganization with an affiliated
fund and reorganization with a third-party fund, and First Trust’s determination recommendation that the
Reorganization was the best option for existing shareholders of the Acquired Fund. As set forth herein, the Board noted the small size
of the Acquired Fund and the potential benefits of being a shareholder in a larger fund; that the Reorganization is expected to qualify
as a tax-free reorganization whereas a liquidation may result in a taxable event for shareholders; the benefits of a closed-end fund structure
versus an open-end fund structure; and abrdn's experience managing and operating closed-end funds. In addition, the Board noted that First
Trust indicated that there was no similar global infrastructure product for a reorganization with an affiliated fund.

Comments provided on December 13, 2023

Comments applicable to each Proxy Statement/Prospectus

Comment
1: In connection with the response to Comment 2 provided on November 21, 2023, please further revise the disclosure
below the second table of the net total annual operating expense ratios, including interest expense, that the Adviser can recoup waived
expenses.

Response:
abrdn Total Dynamic Dividend Fund undertakes to revise the disclosure in the Proxy Statement/Prospectus to be filed pursuant to Rule 424
in response to this comment by adding the following:

“The net total annual operating
expense ratios, including interest expense, in this table of the Acquiring Fund and Combined Fund reflect reimbursement of advisory fees
waived and other expenses reimbursed from abrdn Investments Limited (“aIL”), which can be recouped under certain circumstances
by aIL.”

abrdn
Global Infrastructure Income Fund undertakes to revise the disclosure in the Proxy Statement/Prospectus to be filed pursuant to
Rule 424 in response to this comment by adding the following:

“The net total annual operating
expense ratios, including interest expense, in this table of the Acquiring Fund and Combined Fund reflect reimbursement of advisory fees
waived or reduced and other payments remitted by abrdn Inc. and other expenses reimbursed from abrdn Inc., which can be recouped under
certain circumstances by abrdn Inc.”

Comments applicable to abrdn Total Dynamic
Dividend Fund’s Proxy Statement/Prospectus only

Comment
2: In the “Proposal—Background and Reasons for the Proposed Reorganization” section and “Board
Consideration of the Reorganization” sub-section, it is disclosed that “[t]he Board considered that the Reorganization may
have the additional benefit of reducing the likelihood of an activist campaign against the larger combined fund.” In making the
determination of additional benefits of reducing the likelihood of an activist campaign, please confirm if the Board considered that the
Acquiring Fund was subject to the Control Share Statute contained in Subchapter III of the DSTA while the Acquired Fund is not and disclose
such consideration, if applicable.

Response:
While the Board of the Acquired Fund is aware of control share statutes and related By-laws, they were not a material factor in the Board’s
consideration of the Reorganization.

Comment
3: In connection with the response to Comment 21 provided on November 21, 2023, please further disclose the
Acquiring Fund’s rationale for not broadly exempting application of the Control Share Statute contained in Subchapter III of the
DSTA and whether the Acquiring Fund’s Board considered the provisions and determined that they are in the best interests of the
Acquiring Fund and its shareholders.

Response:
In connection with the Reorganization, the Acquiring Fund’s Board considered whether to exempt any control share acquisitions
in connection with this proxy solicitation. As discussed in the Proxy Statement/Prospectus, all shares will be counted for purposes of
this proxy solicitation. Additionally, the Acquiring Fund’s Board has considered the Control Share Statute and the uncertainty around
the general application under the 1940 Act of state control share statutes and enforcement of control share statutes. The Acquiring Fund’s
Board intends to continue to monitor developments relating to the Control Share Statute and state control share statutes generally.

Comments applicable to abrdn Global Infrastructure
Income Fund’s Proxy Statement/Prospectus only

Comment
4: Please confirm any potential recoupment of previously waived expenses by the Acquiring Fund is accurately reflected
in the pro forma column of the fee table.

Response:
The Registrant so confirms.

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*

Please contact the undersigned at 202-261-3360
should you have any questions regarding this matter.

    Sincerely,

    /s/ Thomas C. Bogle

    Thomas C. Bogle