SecProbe.io

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 April 25, 2025

 Mr. John Kernan
Chief Accounting Office
Securities and Exchange Commission
100 F Street, NE
Washington, DC 20549

 Re: Calamos Global Total Return Fund ("CGO") (File No. 811-2547);
Calamos Convertible and High Income Fund (" CHY ") (File No. 811-21319); Calamos Convertible Opportunities and Income
Fund (" CHI ") (File No. 811-21080); Calamos Global Dynamic Income Fund (" CHW ") (File No. 811-22047)
and Calamos Strategic Total Return Fund (" CSQ ") (File No. 811-21484) (each, a "Registrant" and, collectively,
the "Registrants")

 Dear Mr. Kernan:

 I am writing to respond to the comments of the staff (the "Staff")
of the U.S. Securities and Exchange Commission (the "Commission") that you provided by telephone on March 26, 2025 regarding
certain of the Registrants' reports on Form N-CSR, as noted below filed under the Investment Company Act of 1940, as amended
("1940 Act") for the periods ended October 31, 2024 for each Registrant. Your comments are summarized below, followed
by our responses. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the applicable report.

 1. Comment – The Staff notes that the most recent registration
statements for certain funds state the intent to forward incorporate by reference the most recent annual reports, but Form N-CSR
filings do not consistently include an auditor's consent. For example, the Calamos Global Total Return Fund filed an auditor's
consent with its prior year Form N-CSR 1 but omitted to file an auditor's consent in the current year 2 .
For applicable funds, please confirm the intent to incorporate the annual reports by reference and if applicable, please amend and refile
Form N-CSR with an appropriate auditor's consent. As Staff had a similar comment in prior correspondence, please explain what
steps will be taken to enhance internal controls surrounding this process.

 Response
 – The Registrant (CGO) was not required to file an auditor's consent with its Form N-CSR filed on December 27, 2024
given that CGO was not engaged in continuous at-the-market shelf offering as of October 31, 2024. CGO's shelf registration
statement expired on March 1, 2024, and was not renewed. The Registrant reviewed the N-CSR filing so only those Calamos closed-end
funds with active shelf registration statements included the auditor's consent and the forward incorporation disclosure. The Registrant
believes that the filings were in line with controls in light of earlier comments on a similar issue. Each Fund was filed with the appropriate
disclosure and auditor's consents only if an active shelf registration statement was in place as of October 31, 2024.

 1
See Form N-CSR filed Dec. 29, 2023 -- Consent of Independent Registered Public Accounting Firm dated December 20, 2023 (Ex. 99.(A)(2)(XIV).

 2
See Form N-CSR filed Dec. 27, 2024.

 2. Comment – For open written options contracts, please
disclose all information required by Reg S-X 12-13 3 in columns A through G, including the counterparty.

 Response
 – The Registrant notes that open written options contracts held by the Calamos Funds are all exchange traded options
and, as such, disclosure of the counterparty was not required by Reg S-X 12-13 4 .
The Registrant, in future filings, will update the Schedule of Investments header to reflect "Exchange Traded Written Options."

 3. Comment – Please provide an analysis citing applicable
sections of ASC 820 Fair value measurements, other applicable accounting and regulatory guidance, and the Registrants' valuation
policies and procedures supporting the classification of written options by certain Registrants as Level 1 in the ASC 820 Fair Valuation
Hierarchy. In your response, if applicable, please describe the active markets referenced for identical assets as a basis for your categorization.

 Response
 – The Registrant notes that open written options contracts held by Registrants are all exchange traded options and, as such, were
Level 1 investments. Under ASC 820 these are considered quoted prices (unadjusted) in active markets for identical assets or liabilities
that the reporting entity can access at the measurement date. 5
The Registrant, in future filings, will update the ASC 820 leveling table in the Notes to Financials to reflect "Exchange Traded
Written Options."

 4. Comment – Please provide an analysis citing applicable
US GAAP and other applicable accounting guidance supporting the Registrants' disclosure of securities lending activities undertaken
by State Street Bank and Trust Company ("SSBT") on the Registrants' behalf pursuant to the Amended and Restated Liquidity
Agreement (the "SSB Agreement"). In your response, please explain why it is not appropriate to disaggregate and fully disclose
the securities lending activities undertaken pursuant to the SSB Agreement in the financial statements.

 Response
 – Under the SSB Agreement, the securities lending loans are overnight and continuous. To satisfy the quantitative disclosure requirement
ASU 2014-11 in paragraph 860-30-50-7, the Registrant, in future filings, will add the following language to the Notes to Financials: "The
securities on loan are collateralized by cash collateral received and not securities as disclosed in the Statement of Assets and Liabilities
and the Schedule of Investments. The contractual maturity of the collateral received under the securities lending agreement is classified
as overnight and continuous."

 3
See Reg. S-X, §210.12-13 Open Option Contracts Written.

 4
Ibid. See Column B and footnote 4 – "Not required for exchange traded or centrally cleared options."

 5
See FASB Accounting Standards Update, No. 2022-03 – June 2022, Fair Value Management (Topic 820). "Inputs to Valuation Techniques,
General Principles, 820-10-35-36B – which states in part: "In all cases, if there is a quoted price in an active market (that
is, a Level 1 input) for an asset or a liability, a reporting entity shall use that quoted price without adjustment when measuring fair
value, except as specified in paragraph 820-10-35-41C."

 We hope that the foregoing responses adequately address your comments.

 Should you have any further questions or comments, please do not hesitate
to contact me at (630) 245-8394.

 Very truly yours,

 /s/
 J. Christopher Jackson

 J. Christopher Jackson

 Assistant Secretary

 cc:

 John P. Calamos, Sr.

 Paulita A. Pike, Esq.

 Rita Rubin, Esq.

 Elizabeth L. Madsen, Esq.

 Erik D. Ojala, Esq.

 Susan Schoenberger, Esq.

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ROPES & GRAY LLP

191 NORTH WACKER DRIVE

32nd FLOOR

CHICAGO, ILLINOIS 60606-4302

WWW.ROPESGRAY.COM

June 7, 2022

Mr. Kenneth Ellington

Securities and Exchange Commission

100 F Street, NE

Washington, DC 20549-4720

Re:                             Calamos Advisors Trust (“Advisors Trust”) (File No. 811-09237); Calamos Convertible and High Income Fund (“CHY”) (File No. 811-21319); Calamos Convertible Opportunities and Income Fund (“CHI”) (File No. 811-21080); Calamos Global Dynamic Income Fund (“CHW”) (File No. 811-22047); Calamos Global Total Return Fund (“CGO”) (File No. 811-21547); and Calamos Strategic Total Return Fund (“CSQ”) (File No. 811-21484) (each, a “Registrant” and, collectively, the “Registrants”)

Dear Mr. Ellington:

I am writing to respond to the comments of the staff (the “Staff”) of the U.S. Securities and Exchange Commission (the “Commission”) that you provided by telephone on May 9, 2022 regarding certain of the Registrants’ reports on Form N-CEN and/or Form N-CSR, as applicable and as noted below filed under the Investment Company Act of 1940, as amended (“1940 Act”) for the periods ended October 31, 2021 for each Registrant other than Advisors Trust and December 31, 2021 for Advisors Trust.  Your comments are summarized below, followed by our responses.  Capitalized terms not otherwise defined herein have the meanings ascribed to them in the applicable report.

Advisors Trust

1.              Comment.  With regard to the Schedule of Investments for the Growth and Income Portfolio, please disclose the end of period interest rate for money market funds, as required by Article 12-12, footnote 4 of Regulation S-X.

Response.  The Registrant will include this information in future filings.

CHY, CHI, CHW, CGO and CSQ

2.              Comment.  The internal control letters attached as exhibits to the Form N-CENs filed on January 12, 2021 are missing the city and state where the report was issued and are therefore not in compliance with Item G.1, Instruction 3 of Form N-CEN. Please include this information in future filings.

Response.  The Registrants will include this information in future filings.

CHW and CGO

3.              Comment. We note that the most recent registration statements for Calamos Global Dynamic Income Fund and Calamos Global Total Return Fund forward incorporate by reference the most recent annual reports, but the annual reports do not include 10 years of financial highlights. Please file an amended Form N-CSR, or a prospectus filed pursuant to Rule 424(b), for each fund that includes 10 years of financial highlights. See General Instruction 3 to Item 4.1 of Form N-2.

Response.  Calamos Global Dynamic Income Fund and Calamos Global Total Return Fund note the Staff’s comment and intend to include 10 years of financial highlights in their semi-annual report for the period ended April 30, 2022, to be filed on or about June 30, 2022. Further, Calamos Strategic Total Return Fund also intends to include 10 years of financial highlights in its semi-annual report for the period ended April 30, 2022, to be filed on or about June 30, 2022. In addition, on a going forward basis, 10 years of data will be included in the Financial Highlights table in each fund’s annual report.

CHW, CGO and CSQ

4.              Comment.  We note that the most recent registration statements for Calamos Global Dynamic Income Fund, Calamos Global Total Return Fund and Calamos Strategic Total Return Fund forward incorporate by reference the most recent annual reports, but the annual reports do not include an auditor’s consent. Please file an amended Form N-CSR for each fund that includes an auditor’s consent.

Response.  The Registrants have each filed an amended Form N-CSR to include an auditor’s consent. The amended Form N-CSRs for Calamos Global Dynamic Income Fund and Calamos Strategic Total Return Fund were filed on June 6, 2022. The amended Form N-CSR for Calamos Global Total Return Fund was filed on June 7, 2022.

* * * * *

We hope that the foregoing responses adequately address your comments.

Should you have any further questions or comments, please do not hesitate to contact me at (312) 845-1381.

Very truly yours,

/s/ Elizabeth L. Madsen

Elizabeth L. Madsen, Esq.

cc:

John P. Calamos, Sr.

J. Christopher Jackson, Esq.

Paulita A. Pike, Esq.

2

Rita Rubin, Esq.

Samuel Herling Moore, Esq.

3

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February 26, 2021

Via E-mail and
Edgar

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-0505

Attention: Ms. Lisa Larkin

 Re: Calamos Global Total Return Fund (the “Fund”)

Pre-Effective Amendment No. 2 to the Fund’s
Registration Statement on Form N-2

File Nos. 333-251787 and 811-21547

Ladies and Gentlemen:

Pursuant to Rule 461(a) under
the Securities Act of 1933, as amended (the “Securities Act”), the Fund respectfully requests that the effectiveness
of the above-referenced pre-effective amendment to the Fund’s registration statement on Form N-2 be accelerated to 9:00
a.m. on March 1, 2021, or as soon thereafter as practicable.

The Fund acknowledges that (i) should
the Securities and Exchange Commission (the “Commission”) or its staff (the “Staff”), acting
pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any actions with
respect to the filing, (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring
the filing effective, does not relieve the Fund from its full responsibility for the adequacy and accuracy of the disclosure in
the filing, and (iii) the Fund may not assert this action as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

The Fund also brings to your attention
that pursuant to Rule 430A under the Securities Act, the form of prospectus (including the statement of additional information)
filed as part of the Fund’s registration statement on Form N-2 omits certain information, including information with
respect to the public offering price, discounts or commissions to dealers and other items dependent upon the offering price, delivery
dates, and terms of the securities dependent upon the offering date.

    Very truly yours,

    Calamos Global Total Return Fund

    By:
    /s/ Tammie Lee

    Tammie Lee

    Assistant Secretary

    On Behalf of the Registrant Listed Above

February 26, 2021

Via E-mail and
Edgar

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-0505

Attention: Ms. Lisa Larkin

 Re: Calamos Global Total Return Fund (the “Fund”)

Pre-Effective Amendment No. 2 to the Fund’s
Registration Statement on Form N-2

File Nos. 333-251787 and 811-21547

Ladies and Gentlemen:

Pursuant to Rule 461(a) under
the Securities Act of 1933, as amended (the “Securities Act”), Foreside Fund Services, LLC, the Fund’s
principal underwriter, respectfully requests that the effectiveness of the above-referenced pre-effective amendment to the Fund’s
registration statement on Form N-2 be accelerated to 9:00 a.m. on March 1, 2021, or as soon thereafter as practicable.

    Very truly yours,

    Foreside Fund Services, LLC

    By:
    /s/ Mark Fairbanks

    Name:
    Mark
Fairbanks

    Title:
    Vice-President

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February 19, 2021

Via E-mail and
Edgar

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-0505

Attention: Ms. Lisa Larkin

 Re: Calamos Global Total Return Fund (the “Fund”)

Pre-Effective Amendment No. 1 to the Fund’s
Registration Statement on Form N-2

File Nos. 333-251787 and 811-21547

Ladies and Gentlemen:

Pursuant to Rule 461(a) under
the Securities Act of 1933, as amended (the “Securities Act”), the Fund respectfully requests that the effectiveness
of the above-referenced pre-effective amendment to the Fund’s registration statement on Form N-2 be accelerated to 9:00
a.m. on March 1, 2021, or as soon thereafter as practicable.

The Fund acknowledges that (i) should
the Securities and Exchange Commission (the “Commission”) or its staff (the “Staff”), acting
pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any actions with
respect to the filing, (ii) the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring
the filing effective, does not relieve the Fund from its full responsibility for the adequacy and accuracy of the disclosure in
the filing, and (iii) the Fund may not assert this action as a defense in any proceeding initiated by the Commission or any
person under the federal securities laws of the United States.

The Fund also brings to your attention
that pursuant to Rule 430A under the Securities Act, the form of prospectus (including the statement of additional information)
filed as part of the Fund’s registration statement on Form N-2 omits certain information, including information with
respect to the public offering price, discounts or commissions to dealers and other items dependent upon the offering price, delivery
dates, and terms of the securities dependent upon the offering date.

    Very truly yours,
 Calamos Global Total Return Fund

    By:
     /s/ Tammie Lee

    Tammie Lee

    Assistant Secretary

    On Behalf of the Registrant Listed Above

February 19, 2021

Via E-mail and
Edgar

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-0505

Attention: Ms. Lisa Larkin

 Re: Calamos Global Total Return Fund (the “Fund”)

Pre-Effective Amendment No. 1 to the Fund’s
Registration Statement on Form N-2

File Nos. 333-251787 and 811-21547

Ladies and Gentlemen:

Pursuant to Rule 461(a) under
the Securities Act of 1933, as amended (the “Securities Act”), Foreside Fund Services, LLC, the Fund’s
principal underwriter, respectfully requests that the effectiveness of the above-referenced pre-effective amendment to the Fund’s
registration statement on Form N-2 be accelerated to 9:00 a.m. on March 1, 2021, or as soon thereafter as practicable.

    Very truly yours,

    Foreside Fund Services, LLC

    By:
     /s/ Mark Fairbanks

    Name:
    Mark Fairbanks

    Title:
    Vice-President

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February 8, 2021

Ms. Lisa N. Larkin

Securities and Exchange Commission

100 F Street, NE

Washington,
DC 20549-4720

 Re: Calamos Global Total Return (File Nos. 333-251787, 811-21547) (the “Registrant”
or the “Fund”)

Dear Ms. Larkin:

This letter is in response to the comment
of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that
you provided by telephone on January 27, 2021, with respect to the Registrant’s registration statement on Form N-2 filed
with the Commission pursuant to the Securities Act of 1933, as amended (the “Securities Act”), and the Investment
Company Act of 1940, as amended (“1940 Act”), on December 29, 2020 (the “Registration Statement”).
We have, for the convenience of the Staff, repeated below the comment followed by the Fund’s response.

We respectfully submit this response letter
on behalf of the Registrant. We believe that the disclosure changes discussed in this letter resolve the matters raised. The Registrant
is filing this response in advance of filing of Pre-Effective Amendment No. 1 to the Registration Statement. Capitalized terms
not otherwise defined herein have the meanings ascribed to them in the Registration Statement.

PROSPECTUS

 1. Comment. The Staff notes the following disclosure on the cover page of the prospectus:

“Investing in our securities
involves certain risks, including the risks associated with the Fund’s use of leverage. You could lose some or all of your
investment. See “Risk Factors” beginning on page xx of this prospectus. Shares of closed-end investment companies frequently
trade at a discount to their net asset value and this may increase the risk of loss to purchasers of our securities. You should
consider carefully these risks together with all of the other information contained in this prospectus and any prospectus supplement
before making a decision to purchase our securities.”

Please include a reference to
the risk of junk bonds.

Response. The Registrant has
revised the disclosure to read as follows:

“Investing in our securities
involves certain risks, including the risks associated with investing in securities rated below investment grade, commonly referred
to as “junk bonds,” and the Fund’s use of leverage. You could lose some or all of your investment. See “Risk
Factors” beginning on page xx of this prospectus. Shares of closed-end investment companies frequently trade at a discount
to their net asset value and this may increase the risk of loss to purchasers of our securities. You should consider carefully
these risks together with all of the other information contained in this prospectus and any prospectus supplement before making
a decision to purchase our securities.”

 2. Comment. Please confirm that pursuant to the FAST Act, Registrant will comply with the requirement
to hyperlink the Table of Contents.

Response. The Registrant confirms
that the Table of Contents for the prospectus will be hyperlinked.

 3. Comment. On page 2 of the prospectus, in the second paragraph in the section titled “Dividends
and Distributions on Common Shares,” “return of capital” is referenced for the first time. Please disclose in
plain English what is “return of capital.”

Response: Registrant has added
the following to the second paragraph: “A return of capital is a return of all or a portion of a shareholder’s investment
in the Fund.”

 4. Comment. We note that the Fund will invest in convertible securities. If the Fund expects
to invest in contingent convertible securities (“CoCos”), the Fund should consider what, if any, disclosure is appropriate.
The type and location of disclosure will depend on, among other things, the extent to which the Fund invests in CoCos, and the
characteristics of the CoCos, (e.g., the credit quality, the conversion triggers). If CoCos will be a principal type of
investment, the Fund should provide a description of them and should provide appropriate risk disclosure. In addition, please supplementally
inform us whether, and what amount, the Fund intends to invest in CoCos.

    2

Response. The Registrant does not currently anticipate
investing in contingent convertible securities as a principal investment strategy, but reserves the right to do so in the future.
Accordingly, the Registrant respectfully submits that the disclosure as written accurately reflects the Registrant’s principal
investment strategies and principal investment risks.

 5. Comment. Please consider listing the risks in the summary and statutory sections of the prospectus in order of importance rather
than alphabetically, as suggested by Dalia Blass in her Keynote Address during the ICI Securities Law Developments Conference (Oct.
25, 2018).

Response: The Registrant respectfully declines to
make the Staff’s requested change at this time. In addition to the Director’s speech cited above, the Registrant acknowledges
that it is aware of the non-binding guidance issued by the Division of Investment Management’s Disclosure Review and Accounting
Office titled “Improving Principal Risks Disclosure” (https://www.sec.gov/investment/accounting-and-disclosure-information/principal-risks/adi-2019-08-improving-principal-riskss-disclosure)
(“ADI-2019-08”). While the Registrant respects the Staff’s view on principal risk disclosure, ADI-2019-08
states clearly that the update is not a rule, regulation or statement of the Commission. Moreover, Form N-2 does not require that
a fund’s principal risks be set forth in any particular order. Further, the Registrant believes that ordering the principal
risks alphabetically makes it easier for an investor to find particular risk factors of the Fund. In addition, the materiality
of each risk is fluid, i.e., what is the most material risk today may not be the most material risk tomorrow. Recent market
disruptions and volatility as a result of the global COVID-19 pandemic demonstrate that it is not possible to anticipate which
risk will present the greatest risk to the Registrant at any given moment. Therefore, given the Fund’s broad, multi-sleeved
investment mandate, the Registrant believes that emphasizing one risk over another in a static document in a non-static market
would not be appropriate.

Notwithstanding, the foregoing, the Registrant respectively
notes that it has the following disclosure at the beginning of the “Fund Risks” section in the statutory and summary
portions of the Fund’s prospectus to help investors better understand the importance of reading each risk disclosure regardless
of their sequence:

“The principal risks are presented in alphabetical
order to facilitate finding particular risks and comparing them with other funds. Each risk summarized below is considered a “principal
risk” of investing in the Fund, regardless of the order in which it appears.”

 6. Comment. On page 64, in the second paragraph in the section titled “Closed-End Fund Structure”, it states
                                                               “The Board of Trustees might also consider converting the Fund to an open-end mutual fund, which would also require a
                                                               vote of the shareholders of the Fund.” Please describe
what factors the Board would consider in converting the Fund to an open-end mutual fund.

    3

Response. In determining whether to submit to the
Registrant’s shareholders a proposal to convert to an open-end company, the Board of Trustees would consider all factors
it determined to be relevant, including, potentially and without limitation, the relationship of the market price of the Common
Shares to net asset value, the extent to which the Registrant’s capital structure is leveraged and the possibility of re-leveraging,
the spread, if any, between the yields on securities in the Registrant’s portfolio and interest and dividend charges on outstanding
borrowings or any preferred shares issued by the Registrant and general market and economic conditions.

 7. Comment. The Staff notes that Registrant filed a Form 8-K on January 12, 2021. On page 91, in the section titled “Incorporation
By Reference”, please add the following to the end of paragraph two “provided, however, that the information “furnished”
under Item 2.02 or Item 7.01 of Form 8-K, or other information "furnished" to the SEC which is not deemed filed is not
deemed incorporated by reference into this filing, unless the Registrant specifically states that the information is to be considered
 “filed” under the Exchange Act or incorporates it by reference into a filing under the Securities Act or the Exchange
Act.” Additionally, please list the Form 8-K and Form N-CEN that were recently filed by Registrant to the bulleted list,
which appears after paragraph two.

Response. The Registrant has updated paragraph two
and the bulleted list as follows (new text in bold):

“The
documents listed below, and any reports and other documents subsequently filed with the SEC pursuant to Rule 30(b)(2) under the
1940 Act and Sections 13(a), 13(c), 14 or 15(d) of the Exchange Act, prior to the termination of the offering will be incorporated
by reference into this Prospectus and deemed to be part of this Prospectus from the date of the filing of such reports and
documents, provided, however, that the information “furnished” under Item 2.02 or Item 7.01 of Form
8-K, or other information "furnished" to the SEC which is not deemed filed is not deemed incorporated by reference into
this filing, unless the Registrant specifically states that the information is to be considered “filed” under the Exchange
Act or incorporates it by reference into a filing under the Securities Act or the Exchange Act.

    ■
    the Fund’s Statement of Additional Information, dated [ ], 2021, filed with this Prospectus;

    4

    ■
    the Fund’s Annual Report on Form N-CSR, filed on December 30, 2020;

    ■
    the Fund’s description of Common Shares on Form 8-1, filed on June 28, 2012.;

    ■
    the Fund’s Form 8-K, filed on January 12, 2021.

The Registrant notes that General Instruction F to
Form N-2 requires the Registrant to incorporate by reference reports filed pursuant to Section 13 of the Exchange Act. While Form
N-CEN is required by Rule 30a-1 under the 1940 Act, it is not required pursuant to Section 13 of the Exchange Act. Moreover, the
Registrant submits that it would be inappropriate to incorporate into the Registration Statement “census-type” structured
data intended to be utilized by the Commission that is not otherwise required to be delivered to the Registrant’s shareholders.
Accordingly, the Registrant respectfully declines to incorporate by reference the Registrant’s Form N-CEN.

    5

STATEMENT OF ADDITIONAL INFORMATION

 8. Comment. On page B-1, “Description of Ratings”, there is a footnote 1 marker, but the associated footnote is missing.
Please revise.

Response. The Registrant will revise the formatting
so that the footnote appears on the same page as the footnote marker.

SIGNATURE PAGE

 9. Comment. The Staff notes that for an initial registration statement, the Powers of Attorneys referenced by the Signature Page
should be dated within six months of the date of the initial registration statement. Please file updated Powers of Attorneys.

Response. Rule 483(b) under the Securities Act provides
that powers of attorney filed with the Commission shall relate to a specific filing, but does not indicate that a power of attorney
must relate to a specific filing and no other filing. The powers attorney filed with the Registration Statement clearly contemplate
the Registration Statement and are, furthermore, consistent with powers of attorney used by registrants throughout the industry,
as well as those used by other Calamos funds in connection with registration statements that have been declared effective by the
Commission. Accordingly, the Registrant respectfully declines to file new powers of attorney at this time.

* * * * *

We hope that the foregoing responses adequately
address your comments.

Should you have any further questions or
comments, please do not hesitate to contact me at (630) 245-1105.

Sincerely,

/s/Tammie Lee

Tammie Lee

Cc: J. Christopher Jackson, Calamos Investments

Paulita Pike, Ropes & Gray LLP

Rita Rubin, Ropes & Gray LLP

    6

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calamos
GLOBAL TOTAL RETURN FUND

2020
Calamos Court

Naperville,
Illinois 60563

June
25, 2018

Securities
and Exchange Commission

100
F Street NE

Washington,
DC 20549-4720

Attention:
Ms. Lisa Larkin

    Re:
    Calamos Global Total Return Fund (the “Fund”)

    Pre-Effective Amendment No. 1 to the Fund’s Registration
Statement on Form N-2

    (File Nos. 811-21547 and 333-224205)

Dear
Ms. Larkin:

Pursuant
to Rule 461(a) under the Securities Act of 1933, as amended (the “Securities Act”), the Fund respectfully requests
that the effectiveness of the above-referenced pre-effective amendment to the Fund’s registration statement on Form N-2
be accelerated to 9:00 a.m. on June 27, 2018, or as soon thereafter as practicable.

The
Fund acknowledges that (i) should the Securities and Exchange Commission (the “Commission”) or its staff (the
“Staff”), acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission
from taking any actions with respect to the filing, (ii) the action of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the Fund from its full responsibility for the adequacy and accuracy
of the disclosure in the filing, and (iii) the Fund may not assert this action as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

The
Fund also brings to your attention that pursuant to Rule 430A under the Securities Act, the form of prospectus (including the
statement of additional information) filed as part of the Fund’s registration statement on Form N-2 omits certain information,
including information with respect to the public offering price, discounts or commissions to dealers and other items dependent
upon the offering price, delivery dates, and terms of the securities dependent upon the offering date.

    Very
truly yours,

    Calamos
Global Total Return Fund

    By:
     /s/ Curtis Holloway

    Name:
    Curtis Holloway

    Title:
    Chief Financial Officer and Treasurer

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    ROPES
        & GRAY LLP
 191 NORTH WACKER DRIVE

        32nd FLOOR

        CHICAGO, ILLINOIS 60606-4302
 WWW.ROPESGRAY.COM

June 19, 2018

Ms. Lisa N. Larkin

Securities and Exchange Commission

100 F Street, NE

Washington,
DC 20549-4720

 Re: Calamos Global Total Return (File Nos. 333-224205, 811-21547) (the “Registrant”
or the “Fund”)

Dear Ms. Larkin:

This letter is in response to the comment of
the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that
you provided by telephone on June 14, 2018, with respect to the Registrant’s registration statement on Form N-2 filed with
the Commission pursuant to the Securities Act of 1933, as amended (the “Securities Act”), and the Investment
Company Act of 1940, as amended (“1940 Act”), on April 9, 2018 (the “Registration Statement”). We
have, for the convenience of the Staff, repeated below the comment followed by the Fund’s response.

We respectfully submit this response letter
on behalf of the Registrant. We believe that the disclosure changes discussed in this letter resolve the matter raised. The Registrant
is filing this response in advance of filing of Pre-Effective Amendment No. 1 to the Registration Statement. Capitalized terms
not otherwise defined herein have the meanings ascribed to them in the Registration Statement.

PROSPECTUS

 1. Comment. The Staff notes the following disclosure on page six relating to “Foreign
Securities”:

Under normal circumstances, the Fund
will invest at least 30% of its managed assets in securities of foreign issuers; however, the Fund anticipates that ordinarily
Calamos’ investment process will result in the Fund investing at least 40% of its managed assets in securities of foreign
issuers.

In light of the use of the term “global”
in the Fund’s name, please modify this policy to state that the Fund will normally invest at least 40% of its managed assets
in securities of foreign issuers. Please make this change in all applicable locations.

Response. The requested
change has been made. In response to the Staff’s comment, the Registrant has modified the policy, in all applicable locations,
as follows:

Under normal circumstances, the Fund
will invest at least 30 40% of its managed assets in securities of foreign issuers.; however,
the Fund anticipates that ordinarily Calamos’ investment process will result in the Fund investing at least 40% of its managed
assets in securities of foreign issuers.

* * * * *

We hope that the foregoing response adequately
addresses your comment.

Should you have any further questions or comments,
please do not hesitate to contact me at (312) 845-1376.

    Very truly yours,

    /s/ Matthew A. Brunmeier

    Matthew A. Brunmeier, Esq.

MB/cc:

        John P. Calamos, Sr., Chairman, Trustee and President, Calamos Global
        Total Return Fund

        J. Christopher Jackson, Esq., Vice President and Secretary, Calamos
        Global Total Return Fund

    Jeremy C. Smith, Esq., Ropes & Gray LLP

Paulita A. Pike, Esq., Ropes & Gray LLP

    2

CORRESP
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    ROPES
        & GRAY LLP
 191 NORTH WACKER DRIVE

        32nd FLOOR

        CHICAGO, ILLINOIS 60606-4302
 WWW.ROPESGRAY.COM

June 15, 2018

Ms. Lisa N. Larkin

Securities and Exchange Commission

100 F Street, NE

Washington,
DC 20549-4720

 Re: Calamos Global Total Return (File Nos. 333-224205, 811-21547) (the “Registrant”
or the “Fund”)

Dear Ms. Larkin:

This letter is in response to the comments
of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) that
you provided by telephone on May 1, 2018, with respect to the Registrant’s registration statement on Form N-2 filed with
the Commission pursuant to the Securities Act of 1933, as amended (the “Securities Act”), and the Investment
Company Act of 1940, as amended (“1940 Act”), on April 9, 2018 (the “Registration Statement”). We
have, for the convenience of the Staff, repeated below the comments followed by the Fund’s response.

We respectfully submit this response letter
on behalf of the Registrant. We believe that the disclosure changes and supplemental responses discussed in this letter resolve
the matters raised. The Registrant is filing this response in advance of filing of Pre-Effective Amendment No. 1 to the Registration
Statement. Capitalized terms not otherwise defined herein have the meanings ascribed to them in the Registration Statement.

PROSPECTUS

Outside Front Cover

 1. Comment. In the paragraph that cross-references “Risk Factors,” please explicitly
add a cross-reference to the prospectus discussion regarding the risks associated with leverage. See Item 1.1.j. of Form
N-2.

Response.
The Registrant has added the requested cross-reference as follows: Investing in our securities involves certain risks, including
the Fund’s use of leverage. You could lose some or all of your investment. See “Risk Factors” beginning
on page [ ] of this prospectus.

Prospectus Summary – The Offering

 2. Comment. Please provide additional disclosure if the Fund intends to issue preferred shares
within one year from the effective date of the Registration Statement. Otherwise, please confirm supplementally that the Fund does
not intend to do so.

Response.
The Registrant confirms that it has no present intention of offering additional preferred shares within one year from the effective
date of the Registration Statement. The Registrant also notes supplementally that the Fund completed an offering of mandatory redeemable
preferred shares (“MRP Shares”) in September 2017. The Registrant believes that the Fund’s Registration Statement
adequately addresses the completed offering of MRP Shares, including the consequences to common shareholders.

Prospectus
Summary – Investment Policies

 3. Comment. The Staff notes that the Fund will invest in convertible securities. If the Fund
expects to invest in contingent convertible securities (“CoCos”), the Fund should consider what, if any, disclosure
is appropriate. The type and location of disclosure will depend on, among other things, the extent to which the Fund invests in
CoCos, and the characteristics of the CoCos, (e.g., the credit quality, the conversion triggers). If CoCos will be a principal
type of investment, the Fund should provide a description of them and should provide appropriate risk disclosure. In addition,
please supplementally inform us whether, and what amount, the Fund intends to invest in CoCos.

Response.
The Registrant does not anticipate investing significantly in contingent convertible securities, but reserves the right to do so
in the future. Accordingly, the Registrant respectfully declines to add additional disclosure at this time.

 4. Comment. The Staff notes the following disclosure on page six relating to “Foreign
Securities”:

Under normal circumstances, the Fund
will invest at least 30% of its managed assets in securities of foreign issuers; however, the Fund anticipates that ordinarily
Calamos’ investment process will result in the Fund investing at least 40% of its managed assets in securities of foreign
issuers.

In light of the use of the term “global”
in the Fund’s name, please consider clarifying this policy to state that the Fund will normally invest at least 40% of its
managed assets in securities of foreign issuers.

Response. The Registrant
notes that the adopting release for Rule 35d-1, Release No. IC-24828 (January 17, 2001) stated that “The term “foreign”
indicates investments that are tied economically to countries outside the United States, and an investment company that uses this
term would be subject to the 80% requirement. The terms “international” and “global,” however, connote
diversification among investments in a number of different countries throughout the world, and “international” and
“global” funds will not be subject to the rule. We would expect, however, that investment companies using these terms
in their names will invest their assets in investments
that are tied economically to a number of countries throughout the world. See Proposing Release, supra note 7, at 10960 n.38 and
accompanying text (“The Division no longer distinguishes the terms ‘global’ and ‘international.’”).”

    2

The Registrant expects that under
normal market conditions the Fund’s investment strategy will result in a portfolio that includes investments in a meaningful
number of different countries.  While the Staff’s proposed 40% allocation to foreign countries may represent a reasonable
general expectation over a longer time period for a diversified “global” fund that does not concentrate in particular
groups of industries, imposing a strict investment limitation of this nature would limit the Fund’s portfolio managers’
ability to shift allocations between U.S. and foreign investments based on their relative attractiveness in changing markets.

The fact that the Commission, in
proposing and adopting Rule 35d-1, expressly considered and declined to make subject to that rule a name that includes the term
“global” suggests that such names do not imply a minimum foreign investment.  Accordingly, the Registrant believes
that the Fund’s policy is consistent with Section 35(d) of the 1940 Act and respectfully declines to add additional disclosure
at this time.

 5. Comment. The Staff notes the following disclosure on page seven relating to “Foreign
Securities”:

In analyzing the foreign issuers in
which the Fund may invest, Calamos will generally consider a number of factors that may characterize the issuer’s economic
ties to a particular foreign country or region. Such factors may include any or all of the following: the characteristics of the
economy in the principal country or countries in which the issuer sells its goods and/or services; the stability of the currency
in the issuer’s country of organization; the laws with respect to international trade and property rights in the issuer’s
country of organization; and the tax, accounting and regulatory requirements of the issuer’s country of organization.

Please consider clarifying your economic
tie test to be consistent with the proposed factors for determining whether an investment relates to a particular geographic region
that are described in footnote 24 of the adopting release for Rule 35d-1 under the 1940 Act.

Response.
The Registrant believes that the factors identified in the disclosure convey clearly to the reader that Calamos utilizes a
multi-factor, holistic approach to determining if a given foreign issuer is economically tied to a particular country or
region. In the Registrant’s view, the complexity of modern corporate organizations, the variety of sources and
locations of their revenues and other quantitative measures of their businesses, and the geographic scope of their business
operations are  more adequately addressed by the Registrant’s approach.

 6. Comment. Please discuss, supplementally, the extent to which the Fund invests in third-party
hedge funds or private equity funds that are exempt from registration under Section 3(c)(1) or 3(c)(7) of the 1940 Act.

    3

Response.
The Fund does not currently hold interests in any third-party hedge funds or private equity funds that are exempt from registration
under Section 3(c)(1) or 3(c)(7) under the 1940 Act.

 7. Comment. Will the Fund’s investment in zero coupon securities include payment-in-kind
(“PIK”) loans? If so, please disclose that investors will be exposed to typical risks associated with such income being
required to be included in taxable and accounting income prior to receipt of cash, including the following:

 a. The higher interest rates of PIK loans reflect the payment deferral and increased credit risk associated
with these instruments, and PIK instruments generally represent a significantly higher credit risk than coupon loans.

 b. PIK loans may have unreliable valuations because their continuing accruals require continuing judgments
about the collectability of the deferred payments and the value of any associated collateral.

 c. An election to defer PIK interest payments by adding them to loan principal increases the Fund’s
gross assets, thus increasing the adviser’s future base management fees.

 d. Market prices of zero coupon or PIK securities are affected to a greater extent by interest rate
changes and may be more volatile than securities that pay interest periodically and in cash. PIKs are usually less volatile than
zero coupon bonds, but more volatile than cash pay securities.

 e. Because original issue discount income is accrued without any cash being received by the Fund,
required cash distributions may have to be paid from offering proceeds or the sale of Fund assets without investors being given
any notice of this fact.

 f. The deferral of PIK interest increases the loan-to-value ratio, which is a measure of the riskiness
of a loan.

 g. Even if the accounting conditions for income accrual are met, the borrower could still default
when the Fund’s actual payment is due at the maturity of the loan.

 h. Original issue discount creates risk of non-refundable cash payments to the adviser based on non-cash
accruals that may never be realized.

 i. Because original issue discount will be included in the Fund’s “investment company
taxable income” for the year of the accrual, the Fund may be required to make distributions to shareholders to satisfy the
annual distribution requirement applicable to registered investment companies, even where the Fund has not received any corresponding
cash amount. As a result, the Fund may have difficulty meeting the annual distribution requirement necessary to maintain favorable
tax treatment. If the Fund is not able to obtain cash from
other sources, and chooses not to make a qualifying share distribution, it may become subject to corporate-level income tax.

    4

Response.
At this time, the Registrant does not anticipate that zero coupon securities will represent a significant portion of the Fund’s
income. Supplementally, the Registrant notes that the Fund has no present intention of buying zero coupon securities that have
accretion (i.e., phantom income), but rather intends to buy only those that are issued at or above par and redeem at par.
Notwithstanding, the Registrant has added the following risk disclosure to the SAI:

Investments in zero coupon and payment-in-kind
securities are subject to certain risks, including that market prices of zero coupon and payment-in-kind securities generally are
more volatile than the prices of securities that pay interest periodically and in cash, and are likely to respond to changes in
interest rates to a greater degree than other types of debt securities with similar maturities and credit quality. Because zero
coupon securities bear no interest, their prices are especially volatile. And because zero coupon bondholders do not receive interest
payments, the prices of zero coupon securities generally fall more dramatically than those of bonds that pay interest on a current
basis when interest rates rise. However, when interest rates fall, the prices of zero coupon securities generally rise more rapidly
in value than those of similar interest paying bonds. Under many market and other conditions, the market for the zero coupon and
payment-in-kind securities may suffer decreased liquidity making it difficult for the Fund to dispose of them or to determine their
current value. In addition, as these securities may not pay cash interest, the Fund’s investment exposure to these securities
and their risks, including credit risk, will increase during the time these securities are held in the Fund’s portfolio.
Further, to maintain its qualification for treatment as a RIC and to avoid Fund-level U.S. federal income and/or excise taxes,
the Fund is required to distribute to its shareholders any income it is deemed to have received in respect of such investments,
notwithstanding that cash has not been received currently, and the value of paid-in-kind interest. Consequently, the Fund may have
to dispose of portfolio securities under disadvantageous circumstances to generate the cash, or may have to leverage itself by
borrowing the cash to satisfy this distribution requirement. The required distributions, if any, would result in an increase in
the Fund’s exposure to these securities.

Summary
of Fund Expenses

 8. Comment. Please revise the line item “Acquired Fees and Expenses” in the fee
table to read “Acquired Fund Fees and Expenses”.

Response.
The requested change has been made. The fee table line item has been revised to read “Acquired Fund Fees and Expenses”.

    5

The Fund

 9. Comment. Please confirm supplementally that the Fund’s at-the-market offering described
on page 24 has lapsed and that the Fund has not conducted a subsequent offering of its common shares.

Response.
The Registrant confirms that it has not conducted a public offering of its common shares since the Fund’s prior at-the-market
offering ceased in March 2014.

Portfolio
Managers

 10. Comment. Please state the length of time that John P. Calamos, Sr. has served as a portfolio
manager of the Fund. See Item 9.1.c. of Form N-2.

Response.
The Registrant has added disclosure clarifying that John P. Calamos, Sr. has been a Portfolio Manager of the Fund since inception.

STATEMENT
OF ADDITIONAL INFORMATION

Management
of the Fund

 11. Comment. In the Trustee biography table on page S-26, please update the “Principal
Occupation(s) During the Past 5 Years and Other Directorships” column to state the principal business of any company listed,
unless the principal business is implicit in its name. See Instruction 3 to Item 18.1 of Form N-2.

Response.
The Registrant has added clarifying parentheticals that state the principal business of companies listed, as applicable. For Jack
E. Neal, the Registrant has updated the information as follows: Private investor; Director, Equity Residential Trust (publicly-owned
REIT); Director, Creation Investments (private international microfinance company); Partner, Linden LLC (health care private equity);
Director, Centrust Bank (Northbrook Illinois community bank); Director, Neuro-ID (private company providing prescriptive analytics
for the risk industry). For William R. Rybak, the Registrant has updated the information as follows: Private investor; Chairman
(since February 2016) and Director (since February 2010), Christian Brothers Investment Services Inc.; Trustee, JNL Series Trust,
JNL Investors Series Trust; JNL Strategic Income Fund LLC and JNL Variable Fund LLC (open-end mutual funds) (since January 2007);
Trustee, Lewis University (since October 2012); Director, Private Bancorp (2003-2017); formerly Executive Vice President and Chief
Financial Officer, Van Kampen Investments, Inc. and subsidiaries (investment manager). For David D. Tripple, the Registrant has
updated the information as follows: Private investor; Trustee, Century Growth Opportunities Fund (open-end mutual fund) (since
2010), Cent

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CORRESP

 Calamos Advisors LLC

J. Christopher Jackson

 Calamos
Advisors LLC

 2020 Calamos Court

Naperville, IL 60563-2787

 (630)
245-8394

 October 27, 2016

 VIA EDGAR

 Securities and Exchange Commission

 Division of
Investment Management

 100 F Street, N.E.

 Washington, DC
20549

 Attn: Megan Miller

Re:
Calamos Investment Trust (“Investment Trust”) (File No. 811-05443); Calamos Advisors Trust (“Advisors Trust”) (File No. 811-09237); Calamos Convertible and High Income Fund
(“CHY”) (File No. 811-21319); Calamos Convertible Opportunities and Income Fund (“CHI”) (File No. 811-21080); Calamos Global Dynamic Income Fund (“CHW”) (File No. 811-22047); Calamos
Global Total Return Fund (“CGO”) (File No. 811-21547); and Calamos Strategic Total Return Fund (“CSQ”) (File No. 811-21484) (each, a “Registrant” and, collectively, the
“Registrants”)

 Dear Ms. Miller:

On September 29, 2016, you provided oral comments of the staff (the “Staff”) of the Securities and Exchange Commission (the
“SEC”) regarding the Registrants’ annual reports (each, an “Annual Report” and, collectively, the “Annual Reports”) filed under the Investment Company Act of 1940, as amended (“1940
Act”) on Form N-CSR for the following periods ended: (i) October 31, 2015 for each Registrant except Advisors Trust and (ii) December 31, 2015 for Advisors Trust.

You requested that written responses to the comments be provided via EDGAR correspondence. Accordingly, the Staff’s comments on the Annual
Reports and the Registrants’ responses thereto are set forth below. Capitalized terms not otherwise defined herein have the same meanings set forth in the Annual Reports.

 Investment Trust

Calamos Discovery Growth Fund, Calamos Mid Cap Growth Fund, Calamos Evolving World Growth Fund, Calamos Emerging Markets Equity Fund, Calamos Global Equity
Fund, Calamos Global Growth and Income Fund, Calamos Convertible Fund, Calamos Global Convertible Fund and Calamos Market Neutral Income Fund (for purposes of this response, each, a “Fund” and, collectively, the “Funds”)

1.
Comment: Please add principal risk disclosure in the Funds’ registration statement on Form N-1A relating to “sector risks” where appropriate. For example, it appears as though the Funds each
have had positions in certain sectors that exceed 25% of each Fund’s net assets. On a going-forward basis, consider adding principal risk disclosure relating to the Funds’ focus in any particular sector in the Funds’ registration
statement on Form N-1A, as applicable.

 Response: The Registrant notes that each Fund is actively managed, and as part
of its management duties the investment adviser does an extensive top-down analysis to determine sector overweighting or underweighting for each Fund’s portfolio. As a direct result of this active management, a Fund’s portfolio
composition will vary over time in accordance with the investment adviser’s investment convictions, and the Fund may see significant shifts over time as to which sectors are underweighted or overweighted, the magnitude of that underweighting or
overweighting, and the duration of that investment exposure.

 The variable nature of the each Fund’s active management is reflected in
the Registrant’s current prospectuses, which notes that each Fund intends to invest in a diverse portfolio of securities, and which discusses the investment adviser’s use of a “top-down” investment strategy to diversify by
company, industry, and sector in addition to other criteria. In addition, the Registrant notes that each Fund’s prospectuses also disclose a risk exists that the value of an investment may decrease “if the investment adviser’s
judgment about the attractiveness, value or market trends affecting a particular …sector…is incorrect.”

 Notwithstanding the
foregoing, the Registrant will take the Staff’s comment under advisement, and will consider whether to modify its existing disclosure as part of its annual update to be filed in February of 2017, with an anticipated effectiveness of
March 1, 2017 to add additional disclosure that emphasizes the fact that a Fund may be overweight or underweight one or more sectors in any given period.

All Funds

2.
Comment: The Management Discussion of Fund Performance (“MDFP”) sections disclose that the expense ratios are calculated as of the Funds’ most recent prospectuses. In future filings please
include a statement that such expense ratios may differ from the more recent expense ratios reported in the “Financial Highlights.”

 -2-

 Response: The Registrant will add the following disclosure in future filings: “The
expense ratios shown above may differ from the more recent expense ratios reported in the Financial Highlights section of this report.”

 Calamos
Evolving World Growth Fund, Calamos Global Equity Fund and Calamos Global Growth and Income Fund (for purposes of this response, each, a “Fund” and, collectively, the “Funds”)

3.
Comment: It appears that the expense ratios disclosed in the Funds’ current prospectuses differ slightly from the expense ratios disclosed in the “Financial Highlights.” The Staff also notes that
there is no line item for “Acquired Fund Fees and Expenses.” Please explain why the expense ratios differ.

Response: The variances are due to “Acquired Fund Fees and Expenses” that are less than 0.01% and thus no line item is
reflected in the prospectuses, however the “Acquired Fund Fees and Expenses” are reflected in “Other Expenses” in accordance with Item 3(f)(i) of Form N-1A.

Calamos Market Neutral Income Fund and Calamos Long/Short Fund (for purposes of this response, each, a “Fund” and, collectively, the
“Funds”)

4.
Comment: In future filings please move any expense ratio disclosed in the “Financial Highlights” that excludes dividend or interest expense on short positions to a footnote.

Response: The Registrant will make the requested change in future filings.

Calamos Convertible Fund and Calamos Long/Short Fund (for purposes of this response, each, a “Fund” and, collectively, the “Funds”)

5.
Comment: In future filings please discuss the Funds’ use of derivatives and their impact on Fund performance in the MDFP section. See letter from Barry Miller, Associate Director, Office of Legal and
Disclosure, to Karrie McMillan, Esq., General Counsel, Investment Company Institute, dated July 30, 2010.

Response: The Registrant will make the requested change in future filings in instances where a Fund’s use of derivatives materially
affected its performance during its most recently completed fiscal year.

 Calamos Mid Cap Growth Fund and Calamos Long/Short Fund (for purposes of this
response, the “Funds”)

6.
Comment: Please explain the nature of the “Due to custodian bank” liability listed in the Funds’ “Statement of Assets and Liabilities.”

Response: The amounts are due to security purchases at the end of the reporting period.

 -3-

 All Funds/General

7.
Comment: In future filings please include a parenthetical showing the value of securities on loan in the “Statement of Assets and Liabilities.”

Response: The Registrant respectively declines to make the requested change and notes that the value of securities on loan is disclosed
under “Note 7 – Securities Lending.”

8.
Comment: In future filings please add a statement to the “Notes to Financial Statements” that the Funds adhere to the accounting and reporting requirements set forth in ASU 2013-08 and ASC 946.

 Response: The Registrant will make the requested change in future filings.

9.
Comment: For each Fund with a “tiered” management fee schedule, please consider disclosing the effective management fee rate for the applicable year on a going forward basis.

Response: The Registrant will make the requested change in future filings.

10.
Comment: Please explain the rationale for including the first paragraph directly below the second table on page 153 of the “Notes to Financial Statements.”

Response: The referenced paragraph was inadvertently included. The Registrant will remove the referenced paragraph in future filings.

11.
Comment: If any of the Funds’ expense waivers are subject to recoupment, please consider disclosing in future shareholder reports the dollar amounts of expenses that have been waived and are recoupable under
the expense limitation agreements, along with corresponding expiration dates.

 Response: If any of the Funds’
expense waivers are or become subject to recoupment, the Registrant will make the requested change in future filings.

12.
Comment: Please state whether the Funds engaged in any Rule 17a-7 transactions or participated in any inter-fund lending agreements during the period. If so, please explain why the related-party disclosure set
forth in ASC 850 was omitted. In addition, please confirm that, in general, any Rule 17a-7 transactions are done with appropriate review and oversight by the Registrant’s Board of Trustees.

Response: The Funds did not participate in any Rule 17a-7 transactions or interfund lending agreements during the reporting period. In
addition, the Registrant confirms that Rule 17a-7 transactions are done in accordance with the Funds’ Rule 17a-7 policies and procedures, with appropriate review and oversight by the Registrant’s Board of Trustees.

13.
Comment: For any Fund that is a party to a “Master Netting Agreement,” please disclose, in future filings, the terms of the Agreement, including whether there are any restrictions on received or pledged
collateral.

 -4-

 Response: The Registrant will add the requested disclosure in future filings.
Supplementally, the Registrant notes that the Funds may enter into derivatives transactions, each of which is governed by the terms of a master netting agreement which provides for netting of payment obligations, close-out netting and provision of
collateral. When a Fund is required to post collateral under the terms of a derivatives transaction and master netting agreement, the Fund’s custodian holds the collateral in a segregated account, subject to the terms of a tri-party
agreement among the Fund, the custodian and the counterparty. The master netting agreement and tri-party agreement provide, in relevant part, that the counterparty may have rights to the amounts in the segregated account in the event that the
Fund defaults in its obligation with respect to the derivative instrument that is subject to the collateral requirement. When a counterparty is required to post collateral under the terms of a derivatives transaction and master netting
agreement, the counterparty delivers such amount to the Fund’s custodian. The master netting agreement provides, in relevant part, that the Fund may have rights to such collateral in the event that the counterparty defaults in its
obligation with respect to the derivative instrument that is subject to the collateral requirement.

14.
Comment: In future filings please consider replacing the word “may” with “will” in the following sentence under “Note 8 – Securities Lending”: The Funds may pay reasonable fees
to persons unaffiliated with the Funds for services in arranging these loans. In addition, please indicate whether the securities lending income is shown on a net basis in the “Statement of Operations” and, if not, state why not.

 Response: The Registrant will make the requested change in future filings. In addition, the Registrant notes that the
securities lending income is shown on a net basis.

15.
Comment: In “Supplemental Information,” the Registrant undertook to file a copy of its By-Laws as an exhibit to the annual filing on Form N-SAR. Please file an amended Form N-SAR to include this
exhibit.

 Response: In response to the Staff’s comment, the Registrant filed an amended N-SAR on October 14,
2016. In addition, each other Registrant also filed an amended N-SAR on October 14, 2016 in response to the Staff’s comment given to Investment Trust.

Advisors Trust

 Calamos Growth and Income
Portfolio (for purposes of responses 16-18, the “Fund”)

16.
Comment: It appears that the expense ratio disclosed in the Fund’s current prospectus differs slightly from the expense ratio disclosed in the “Financial Highlights.” Please explain why the expense
ratios differ.

 Response: The variance is due to “Acquired Fund Fees and Expenses” that are less than 0.01%
and thus no line item is reflected in the prospectus, however the “Acquired Fund Fees and Expenses” are reflected in “Other Expenses” in accordance with Item 3(f)(i) of Form N-1A.

 -5-

17.
Comment: In future filings please add a footnote in the “Financial Highlights” stating that total returns do not include fees or expenses charged by insurance products and that if they were shown, the
returns would be lower.

 Response: The following disclosure will be added to future reports: “The expenses do not
reflect the expenses of the variable insurance contracts or the separate account through which you indirectly invest in the Fund, whichever may be applicable, and the total expenses would be higher if they were included.”

18.
Comment: In future filings please include the statement required by Item 27(b)(6) of Form N-1A.

Response: The following statement will be added to the Annual Report for both Investors Trust and Advisors Trust: “The Trust’s
Statement of Additional Information contains additional information about the Trust’s Trustees and Officers and is available without charge, upon request, at www.calamos.com or by calling 800.582.6959.”

Closed-End Funds (CHY, CHI, CHW, CGO and CSQ)

All Funds

19.
Comment: Please consider defining “managed assets” on the Funds’ website and quarterly fact sheets. In addition, please consider including an explanatory note stating that the expense ratios
included in the Funds’ “Financial Highlights” are calculated on net assets and may differ.

 Response:
The Registrants will make the requested changes for periods starting after October 31, 2016.

20.
Comment: In future filings please consider whether there is a more appropriate location for the ISDA disclosure currently contained in Foreign Currency Risk under “Note 6 – Derivative Instruments.”

 Response: The ISDA disclosure pertains to the foreign exchange contracts as well as the swaps. The Registrants will
reference the ISDA language for swap contracts under interest rate risk in future filings.

 CGO (for purposes of this response, the “Fund”)

21.
Comment: In future filings please state whether the Fund has any capital loss carryforwards under “Note 4 – Income Taxes.” If none, please include a statement to that effect.

Response: The Registrant will remove the disclosure related to the RIC Modernization Act changes and will not reference capital loss
carryforwards unless the Fund actually has them.

 -6-

 All Funds

22.
Comment: For variable rate securities in the “Schedule of Investments,” please consider disclosing a description of the base reference rate, the end of period interest rate and spread, if any, on a
going-forward basis. Alternatively, please consider disclosing the end of period rate in a note to the Schedule.

Response: The Registrants will disclose the end of period rate in the Schedule of Investments in future filings.

23.
Comment: In future filings please include the floating rate payment frequency for interest rate swaps (e.g., monthly or quarterly) in the “Schedule of Investments.”

Response: The Registrants will make the requested change in future filings.

24.
Comment: In future filings please move any expense ratio disclosed in the “Financial Highlights” that excludes dividend or interest expense on short positions to a footnote.

Response: The Registrants will make the requested change in future filings.

CHW (for purposes of this response, the “Fund”)

25.
Comment: “Note 1 – Organization and Significant Accounting Policies” indicates that, under normal circumstances, the Fund will invest at least 40% of its managed assets in securities of foreign
issuers. It appears that the Fund

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corresp

    K&L Gates llp

1601 K Street NW
 Washington, DC 20006-1600
 t 202.778.9000     www.klgates.com

August 25, 2011

Mr. Larry Greene

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Calamos Global Total Return Fund

333-174431

811-21547

Dear Mr. Greene:

     This letter responds to your comment letter post-marked July 20, 2011 (the “Letter”) regarding
the registration statement filed on Form N-2 by Calamos Global Total Return Fund (the “Fund”). For
convenience, each of your comments is repeated below, with responses immediately following.

     The revisions to the prospectus, prospectus supplements and statement of additional
information responding to these comments were included in Pre-Effective Amendment no. 1 to the
registration statement, which also updates various financial data of the fund as shown in the
financial statements contained in the Fund’s semi-annual report to shareholders.

General

    1.

    Comment: Please see the U.S. Securities and Exchange Commission, A Plain English Handbook
(1998). Please review and revise the disclosure where it appears necessary so as to assure
conformity with the Commission’s plain English requirements. For example, reformat disclosures
appearing in all capital letters under the caption “Certain Federal Income Tax Matters.”
Please use a different means to make the disclosure prominent. (e.g., bold). Indent the last
two bullet points of the discussion in the fourth paragraph under the caption “Prospectus
Summary — Dividends and Distributions on Common Shares” following the bullet which states “an
offering other than those described above, unless, with respect to such other offering.”
Lastly, delete the redundant statement in the first paragraph of the discussion captioned
“Prospectus Summary — Investment Policies” regarding the Fund’s investment of its managed
assets in foreign issuers.

Mr. Larry Greene

August 25, 2011

Page 2

    Response: We have amended the registration statement in accordance with the staff’s
comments, with the exception of the comment regarding deleting the redundant statement in
the first paragraph of the discussion captioned “Prospectus Summary — Investment Policies.”
We believe that there are no redundant statements in such paragraph and that any
combination of sentences would lead to a less clear presentation, contrary to the
Commission’s plain English requirements. Consequently, we respectively decline to alter
such paragraph.

    2.

    Comment: In light of disclosure regarding the Fund’s contemplated investments in derivative
instruments, confirm that the Fund’s derivatives disclosure reflects the observations set
forth in the recent letter from Barry Miller, Associate Director in the Division of Investment
Management, to the Investment Company Institute. In summary, you should provide more
understandable disclosure on this topic to investors. Funds are encouraged to focus disclosure
on actual anticipated operations rather than a list of investments that they might make. Funds
should tailor their strategy discussion of derivatives to describe the specific instruments in
which the fund invests or will invest principally, and provide risk disclosure to reflect the
types of derivatives used, and the extent of and the purposes of such use. See Letter to
Karrie McMillan, Esq., General Counsel, Investment Company Institute, Derivatives-Related
Disclosures by Investment Companies (July 30, 2010).

    Response: Understood. We have added the following
disclosure to “Prospectus Summary Investment Policies —
Other Securities:”

    The Fund’s derivative activities are principally focused on the following
derivatives: interest rate swaps, convertible securities, synthetic convertible
securities, options on individual securities, index options and forward currency
exchange contracts. However, the Fund reserves the right to invest in other
derivative instruments to the extent it is consistent with the Fund’s investment
objective and restrictions.

    We believe that the nature and potential risks of  each of the Fund’s derivative instruments is sufficiently disclosed in
accordance with the July 30, 2010 Investment Company Institute letter.

    3.

    Comment: Disclosure sub-captioned “Risks Factors — Recent Market Events” contains a
discussion of the recent market turmoil. In light of the continuing economic issues in Europe
involving Greece and Portugal, among other European countries, and the impact that may have on
our domestic economy, please enhance the disclosure accordingly.

    Response: We have revised the disclosure in accordance with the staff’s comments as
follows:

    In the recent past, domestic and international markets have experienced acute
turmoil due to a variety of factors, including economic unrest in Greece,

Mr. Larry Greene

August 25, 2011

Page 3

    Spain, Ireland, Portugal and other European Union countries. This turmoil
resulted in unusual and extreme volatility in the equity and debt markets, in the
prices of individual securities and in the world economy. In addition, many
governments throughout the world responded to the turmoil with a variety of
significant fiscal and monetary policy changes, including but not limited to,
direct capital infusions into companies, new monetary programs and dramatically
lower interest rates. An unexpected or quick reversal of these policies could
increase the volatility in the equity and debt markets. These market conditions and
continuing economic risks could have a significant effect on the domestic and
international economies, and could add significantly to the risk of short-term
volatility in the Fund.

    4.

    Comment: The Amended and Restated Agreement and Declaration of Trust, in Article V, states
that: “All Shares issued hereunder shall be fully paid and non-assessable.” However, Article
VIII provided that: “The Trustees shall have the power, as frequently as they may determine,
to cause each Shareholder, or each Shareholder of any particular Series, to pay directly, in
advance or arrears, for charges of the Trust’s custodian or transfer, shareholder servicing or
similar agent, an amount fixed from time to time by the Trustees, by setting off such charges
due from such Shareholder from declared but unpaid dividends owed such Shareholder and/or by
reducing the number of Shares in the account of such Shareholder by that number of full and/or
fractional Shares which represents the outstanding amount of such charges due from such
Shareholder.” Disclosure in the SAI under the caption “Additional Information Concerning the
Agreement and Declaration of Trust” reiterates the above provision. Please disclose in the
prospectus that the Fund will not make an assessment without prior approval of the staff.

    Response: We acknowledge the staff’s comment regarding Article VIII of the Fund’s
Agreement and Declaration of Trust (the “Trust Agreement”). We note that, as a threshold
matter, the Fund continues to believe that its Commons Shares are fully paid and
non-assessable upon issuance, and that the provision of the Trust Agreement referenced
above is not in the nature of an assessable stock.

    As the staff notes, the Fund currently discloses this provision of its Trust Agreement on
page S-51 of its Statement of Additional Information. The Fund discloses further that it
“has no present intention of relying on this provision of the Agreement and Declaration of
Trust and would only do so if consistent with the 1940 Act or the rules and regulations or
interpretations of the SEC thereunder.” The Fund respectfully submits that this statement
inherently contemplates further discussions between the Fund and the staff prior to such an
implementation, and that the current disclosure is sufficient.

    The Fund respectfully declines to make a broad statement that the Fund “will not make an
assessment without the prior approval of the Staff.” The concept of “approval” necessarily
implies the power to take formal, official action. We are

Mr. Larry Greene

August 25, 2011

Page 4

    unaware of any provision of the Investment Company Act of 1940, or any of the other federal
securities laws that would provide the Securities Exchange Commission, or its staff with
the authority to take formal action on what is essentially a state corporate law matter.
As a result, the Fund is concerned that by making the requested disclosure, the Fund will
be foreclosed from implementing the provision of the charter document — assuming that such
an implementation was ever necessary — because it will be impossible, as a matter of law,
to obtain “approval” of the staff on such a matter.

    We note that this is the approach that the Fund has previously discussed with the staff,
and believes that this approach continues to be the most appropriate way to address the
staff’s concerns.

Prospectus Cover

    5.

    Comment: Update the disclosure regarding the Fund’s last reported sale price referenced in
the fourth paragraph.

    Response: We have updated this information in accordance with the staff’s comments.

    6.

    Comment: Revise the prominent statement appearing at the bottom of the page, the substance
of which is required by Rule 481(b)(l) under the Securities Act to reflect the changes brought
about by the National Securities Markets Improvement Act of 1996.

    Response: We have revised this statement in accordance with the staff’s comments.

Prospectus

    7.

    Comment: Revise the second paragraph of the discussion captioned “Prospectus Summary —
Dividends and Distributions on Common Shares” so as to delete the following indicated clause:
“will be treated by a shareholder for federal income tax
purposes as a tax-free return of
capital”

    Response: We have revised this statement in accordance with the staff’s comments.

    8.

    Comment: Revise the fee table discussion consistent with the following:

    •

    revise the second paragraph following the caption so as to state the information
therein as a percentage of net assets,

    Response: Based on the August 11, 2011 telephone discussion between Eric Purple
and you, we are retaining the reference to managed assets in the
second paragraph, because it more
accurately reflects the percentage of debt as compared to the assets available to
retire the debt. We hereby confirm that all of the amounts in

Mr. Larry Greene

August 25, 2011

Page 5

    the fee table are  presented in terms of net assets, as indicated by the caption to
the second column to the table and by footnote 3.

    •

    in light of each Fund’s planned investments in other investment companies, add an
additional line item for Acquired Fund Fees and Expenses (See Investment Company Act
Release No. 27399 (June 20, 2006)), and

    Response: Understood. We have updated the fee table accordingly.

    •

    lastly, the fee table is substantially blank as is certain other financial
information elsewhere in the filing. We may have comments regarding that Information
upon its inclusion in an amendment to this registration statement.

    Response: We have reviewed the prospectus contained in the registration statement,
and in particular have examined the fee table on page 16 of the prospectus. We
note that all of the information contained in that prospectus is complete, with the
exception of figures for sales load and offering expenses.

    We note that the registration statement is intended to be a universal shelf
offering that is designed to comply with Nuveen Virginia Premium Income Municipal
Fund, SEC Staff No-Action Letter (Oct. 6, 2006) and America Prime Rate Trust, SEC
Staff No-Action Letter (May 1, 1998). As a consequence, the registration statement
contains certain information which will be completed by filing a prospectus
supplement that contains the missing information (e.g., the sales load and offering
expenses). In particular, the registration statement’s “form of” prospectus
supplements for both preferred stock and debt contain a variety of blanks, as the
information related to those securities has not yet been determined. These
prospectus supplements are intended to provide the staff and investors with an
understanding of the nature of the information that will be contained in a
prospectus supplement as it might ultimately be used; there is no present intention
of offering securities using the form-of prospectus supplements without first completing them
and using either a preliminary or final version of the prospectus supplement as
filed pursuant to Rule 497 under the Securities Act of 1933.

    9.

    Comment: The Discussion captioned “Risk Factors — Additional Risks to Common Shareholders”
discloses that: “Certain types of borrowings may result in the Fund being subject to covenants
in credit agreements, including those relating to asset coverage, borrowing base, and
portfolio composition requirements . . . These guidelines may impose asset coverage or
portfolio composition requirements that are more stringent than those imposed by the
1940 Act.” (Emphasis added.) Disclose the consequences of those stricter requirements on the
operation of the Fund.

    Response: We have revised the disclosure  in
“Risk Factors-Additional Risks  to Common Shareholders —
Leverage Risk” in accordance with the staff’s  comment by adding the
following statements:

Mr. Larry Greene

August 25, 2011

Page 6

    Currently, there are no portfolio composition requirements under the Agreement and related Lending Agreement. However, there are limits on
which securities can be treated as pledged collateral for purposes of those
agreements. Calamos does not anticipate that these covenants or restrictions will
adversely affect its ability to manage the Fund’s portfolio in accordance with the
Fund’s investment objective and policies. Due to these covenants or restrictions,
the Fund may be forced to liquidate investments at times and at prices that are not
favorable to the Fund, or the Fund may be forced to forgo investments that Calamos
otherwise views as favorable.

    10.

    Comment: Disclosure a little later in this section indicates that: “The Fund’s net asset
value may be reduced immediately following this offering by the offering costs for common
 shares or other securities, which will be borne entirety by all common shareholders.” As
applicable here, §23(b) of the 1940 Act states: No registered closed-end company shall sell
any common stock of which it is the issuer at a price below the current net asset
value of such stock, exclusive of any distributing commission or discount . . .” (Emphasis
added.) The gross offering proceeds, less commissions, must equal the Fund’s net asset value.
See General Public Service Corporation, (pub. avail. June 24, 1963). Reconcile the
contemplated dilution with the statutory requirement.

    Response: The Fund is aware of its responsibilities under Section 23(b).  Page 58 of
the prospectus,  under the heading, “Description of
Securities-Common Shares,” contains  the following  disclosure:

    Other offerings of common shares, if made, will require approval of the Board of
Trustees and will be subject to the requirement of the 1940 Act that common shares
may not be sold at a price below the then-current net asset value, exclusive of
underwriting discounts and commissions. Common Shares may be sold
in one or more at the market offerings through sales on the NYSE at a price equal
to or above NAV plus any underwriting discounts or sales commissions paid by the Fund to execute such sales.

    We also note that there are other offering costs, outside of
distribution commissions and
discounts, such as legal, accounting and printing fees, that will be borne entirely by the
common shareholders. Such offering costs do not fall under the scope of Section 23(b). In
addition, Section 23(b) does not apply in the case tha

CORRESP
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corresp

Calamos Advisors, LLC

2020 Calamos Court

Naperville, IL 60563

August 25, 2011

BY EDGAR

Securities and Exchange Commission

100 F Street, N.E.

Washington, DC 20549

Ladies and Gentlemen:

Calamos Global Total Return Fund

811-21547

333-174431

     On
behalf of the Calamos
Global Total Return Fund (the “Fund”), we hereby make the following
representations:

     (i) The Fund is responsible for the adequacy and accuracy of the disclosure in its filings
with the Securities and Exchange Commission (the “Commission”);

     (ii) Should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with respect to the
filing;

     (iii) The action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the Fund from full responsibility for the adequacy
and accuracy of the disclosure in the filings; and

     (iv) The Fund may not assert this action as a defense in any proceeding initiated by the
Commission or any person under the Federal securities laws of the United States.

    Calamos Global Total Return Fund

    By:

    /s/ J. Christopher Jackson

    Name:

    J. Christopher Jackson

    Title:

    Vice President and Secretary

CORRESP
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Calamos
Advisors, LLC

2020 Calamos Court

Naperville, Illinois 60563

Phone: 630-245-7200

www.calamos.com

August 25, 2011

OVERNIGHT DELIVERY AND EDGAR

Larry Greene

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Calamos Global Total Return Fund

Registration Statement on Form N-2

File Nos. 333-174431 and 811-21547

Dear
Mr. Greene:

     In
accordance with Rule 461 of the General Rules and Regulations under the Securities Act of
1933, as amended, Calamos Global Total Return Fund (the “Fund”) hereby requests
acceleration of the effective date of the above-captioned Registration Statement so that it will
become effective by 10:00 a.m., Eastern Time, on September 2, 2011 or as soon thereafter as
practicable.

    Sincerely,

CALAMOS GLOBAL TOTAL RETURN FUND

    By:
    /s/ J. Christopher Jackson

    J. Christopher Jackson

    Vice President and Secretary

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549
DIVISION OF
INVESTMENT MANAGEMENT
Eric Purple, Esq.
K&L Gates LLP
1601 K Street, N.W.
Washington, D.C. 20006-1600
Re: Calamos Global Total Return Fund
File Nos. 333-174431,811-21547
(the "Fund")
Dear Mr. Purple:
On May 23,2011, the Calamos Global Total Return Fund (''Total Return Fund"),
filed a registration statement on Form N-2 under the Securities Act of 1933 ("Securities
Act") and the Investment Company Act of 1940 ("1940 Act"). A letter of even date
accompanied the fiing and sought selective review. The fiing was made to update all
financial information and to make other non-matèrial changes. With certain exceptions,
we have limited our review of the filing.
Our comments regarding the filing are set forth below.
General
1. Please see the U.S. Securities and Exchange Commission, A Plain English
Handbook (1998). Please review and revise the disclosure where it appears necessary so
as to assure conformty with the Commission's plain English requirements. For example,
reformat disclosures appearing in all capital letters under the caption "Certain Federal
Income Tax Matters." Please use a different means to make the disclosure promient
(e.g., bold). Indent the last two bullet points ofthe discussion in the fourth paragraph
under the caption "Prospectus Summar - Dividends and Distributions on Common
Shares" following the bullet which states "an offering other than those described above,
unless, with respect to such other offering." Lastly, delete the redundant statement in the
first paragraph ofthe discussion captioned "Prospectus Summary - Investment Policies"
regarding the Fund's investment of its managed assets in foreign issuers.
2. In light of disclosure regarding the Fund's contemplated investments in derivative
instruments, confi that the Fund's derivatives disclosure reflects the observations set
forth in the recent letter from Barr Miler, Associate Director in the Division of
Investment Management, to the Investment Company Institute. In summary, you should
provide more understandable disclosure on this topic to investors. Funds are encouraged
to focus disclosure on, actual anticipated operations rather than a list of investments that
l.: c.""sGdOS22011
1n9miii-l~24:5AM

Page 2 of 4
they might make. Funds should tailor their strategy discussion of derivatives to describe
the specific instruments in which the fund invests or wil invest pricipally, and provide
risk disclosure to reflect the types of derivatives used, and the extent of and the purposes
of such use. See Letter to Karie McMilan, Esq., General Counsel, Investment Company
Institute, Derivatives-Related Disclosures by Investment Companies (July 30,2010).
3. Disclosure sub-captioned "Risks Factors - Recent Market Events" contains a
discussion of the recent market turmoiL. In light of the continuing economic issues in
Europe involving Greece and Portugal, among other European countries, and the impact
that may have on our domestic economy, please enhance the disclosure accordingly.
4. The Amended and Restated Agreement and Declaration of Trust, in Aricle V,
states that: "All Shares issued hereunder shall be fully paid and nonassessable."
However, Aricle VIII provided that: ''The Trustees shall have the power, as frequently as
they may determe, to cause each Shareholder, or each Shareholder of any paricular
Series, to pay directly, in advance or arears, for charges of the Trust's custodian or
transfer, shareholder servicing or similar agent, an amount fixed from time to time by the
Trustees, by setting off such charges due from such Shareholder from declared but unpaid
dividends owed such Shareholder and/or by reducing the number of Shares in the account
of such Shareholder by that number of full and/or fractional Shares which represents the
outstanding amount of such charges due from such Shareholder." Disclosure in the SA!
under the caption "Additional Information Concerning the Agreement and Declaration 0 f
Trut" reiterates the above provision. Please disclose in the prospectus that the Fund wil
not make an assessment without prior approval of the staff
Prospectus Cover
5. Update the disclosure regarding the Fund's last reported sale price referenced in
the fourth paragraph. .
6. Revise the promient statement appearig at the bottom of the page, the substance
of which is required by Rule 481(b)(I) under the Securities Act to reflect the changes
brought about by the National Securities Markets Improvement Act of 1996.
Prospectus
7. Revise the second paragraph ofthe discussion captioned ''Prospectus Summar-
Dividends and Distnbutions on Common Shares" so as to delete the following indicated
clause: ''wil be treaed by a shareholder for federal income tax purpses as a tax free retur ofcapital" .
8. Revise the fee table discussion consistent with the following:
· revise the second paragraph following the caption so as to state the information
therein as a percentage 0 f net assets,
l. Compafi,nosll132O
1n9l2ii-l"24~OAM

Page 3 of 4
. in light of each Fund's planned investments in other investment companies, add
an additional line item for Acquired Fund Fees and Expenses (See Investment
Company Act Release No. 27399 (June 20, 2006)), and
. lastly, the fee table is substantially blank. as is cerai other fiancial informtion
elsewhere in the :fling. We may have comments regarding that information upon its
inclusion in an amendment to this registration statement.
9. The Discussion captioned "Risk Factors - Additional Risks to Common
Shareholders" discloses that: "Certain types ofborrowings may result in the Fund being
subject to covenants in credit agreements, including those relating to asset coverage,
borrowing base and portfolio composition requirements. . . These guidelines may impose
a,set coverage or portfolio composition requirements that are more strigent than those
imposed by the 1940 Act." (Emphasis added.) Disclose the consequences of those
stricter requirements on the operation ofthe Fund.
10. Disclosure a little later in this section indicates that: "The Fund's net asset value
may be reduced immediately following this offering by the offering costs for common
shares or other securities, which wil be borne entirely by all common shareholders." As
applicable here, §23(b) of the 1940 Act states: No registered closed-end company shall
sell any common stock of which it is the issuer at a price below the current net asset value
of such stock, exclusive of any distributing commission or discount. .." (Emphasis
added.) The gross offering proceeds, less commissions, must equal the Fund's net asset
value. See General Public Service Corporation, (pub. avaiL. June 24, 1963). Reconcile
the contemplated dilution with the statutory requirement.
** * * * * * * * * *
We note that portions of the :fling are incomplete. We may have additional
comments on such portions when you complete them in a pre-effective amendment, on
disclosures made in response to this letter, on information supplied in your response
letter, or on exhibits added in any pre-effective amendments.
Whenever a comment is made in one location, it is considered applicable to all
similar disclosure appearing elsewhere in the registration statement.
Response to this letter should be in the form of a pre-effective amendment fied
pursuant to Rule 472 under the Securities Act. Where no change will be made in the
filing in response to a comment, please indicate this fact in your response letter and
briefly state the basis for your position. Where changes are made in response to our
comments provide information regarding the nature ofthe change and, if appropriate, the
location of such new or revised disclosure in the amended filing. As required by the rule,
please insure that you mark new or revised disclosure to indicate change.
Please advise us if you have submitted or expect to submit an exemptive
application or no-action request in connection with your registration statement.
Lo Compcaamsl i l32O
1ß9miii-l~24~OAM

Page 4 of 4
You should review and comply with all applicable requirements ofthe federal
securities laws in connection with the preparation and distribution of a preliminary
prçspectus.
We urge all persons who are responsible for the accuracy and adequacy ofthe
disclosure in the filings reviewed by the staff to be certai that they have provided all
information investors require for an informed decision. Since the Fund and its
management are in possession 0 f all facts relating to the Fund's disclosure, they are
responsible for the accuracy and adequacy of the disclosures they have made.
In the event the Fund requests acceleration ofthe effective date ofthe pending
registration statement, it should furnish a letter, at the time of such request,
acknowledging that
· the Fund is responsible for the adequacy and accuracy of the disclosure in the
filing;
· should the Commssion or the staff, acting pursuant to delegated authority,
declare the filing effective, it does not foreclose the Commission from taking any
action with respect to the filing;
· the action of the Commission or the staff acting pursuant to delegated authority,
in declaring the filing effective, does not relieve the Fund from its full
responsibility for the adequacy and accuracy 0 f the disclosure in the filing; and
· the Fund may not assert this action as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.
In addition, please be advised that the Division of Enforcement has access to all
information you provide to the staff of the Division ofInvestment Management in
connection with our review of your filing or in response to our comments on your fiing.
We wil consider a written request for acceleration of the effective date of the
registration statement as confirmation ofthe fact that those requesting acceleration are
aware oftheir respective responsibilities.
Should you have any questions regarding this letter, please contact me at (202)
551-6976.
~
Thursday, June 30,2011
lo Conipta1aiiosl 1132O
1ß9miii-io-24~OAM

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February 18, 2010

Mr. Larry Greene

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Calamos Global Total Return Fund

333-146944

811-21547

Dear Mr. Greene:

     This letter responds to the comments you verbally conveyed to me on October 8, 2009, regarding
post-effective amendment no. 2 to the registration statement on Form N-2 of Calamos Global Total
Return Fund (the “Fund”). For convenience, each of your comments is repeated below, with responses
immediately following.

     The revisions to the prospectus, prospectus supplements and statement of additional
information responding to these comments were included in a new Post-Effective Amendment no. 3,
which also updates the Fund’s financial statements.

General

    1.

    Comment: Please provide written responses to the staff’s
comments, filed as a separate piece of EDGAR
correspondence. In addition, please file Tandy
representations as EDGAR correspondence.

    Response: The Fund hereby files these responses to the staff’s comments as separate EDGAR
correspondence. The Fund also hereby files Tandy representations with the Commission in
this correspondence, as Exhibit A hereto.

    2.

    Comment: We note that the Fund has the term “Global” in its name. Please supplementally
verify that the Fund is in compliance with Rule 35d-1 under the Investment Company Act of 1940
(the “1940 Act”).

    Response: The Investment Company Names Release No. IC-24828 suggests that a fund that uses
the term “Global” in its name should invest its assets in “investments that are tied
economically to a number of countries throughout the world,” with the

Mr. Larry Greene

February 18, 2010

Page 2

    staff generally interpreting this to require a “global” fund to invest at least 40% of its
assets in non-U.S. securities. During the comment process for the Fund’s initial
registration statement in 2005, we received a comment from the staff regarding the term
“Global” and were able to agree on the language that is currently included in the
prospectus. We believe that the Fund’s policy continues to be in compliance with Rule
35d-1. In addition, as of August 31, 2009, the Fund had over 60% of its managed assets
invested in non-U.S. securities, with eight foreign countries each comprising more than 2%
of the Fund’s portfolio. The Fund’s policy regarding non-U.S. investments, contained on
page 22 of the prospectus, is as follows:

    Under normal circumstances, the Fund will invest at least 30% of its managed assets
in securities of foreign issuers; however, the Fund anticipates that ordinarily
Calamos’ investment process will result in the Fund investing at least 40% of its
managed assets in securities of foreign issuers.

Prospectus

    3.

    Comment: On page ii of the prospectus, the Fund provides a
cautionary notice regarding forward looking
statements. Please consider consolidating the last
sentence of the first paragraph of this discussion
with the last paragraph, which appear to involve
related concepts.

    Response: We have moved the last paragraph on page ii of the prospectus to the end of the
first paragraph.

    4.

    Comment: Please confirm supplementally the staff’s understanding that the phrase “managed
assets” that is used on page 1 of the prospectus includes assets attributable to borrowings.

    Response: We confirm supplementally the staff’s understanding that the phrase “managed
assets” that is used on page 1 of the prospectus includes assets attributable to
borrowings.

    5.

    Comment: On page 1 of the prospectus, the Fund states that it may offer its securities “on an
immediate, continuous, or delayed basis.” Please provide a supplemental explanation that
briefly describes each offering method, and which explains why these methods are not mutually
exclusive.

    Response: The phrase “immediate, continuous, or delayed basis” is taken from Rule
415(a)(1)(x), and it refers to three distinct methods of selling securities. An
“immediate” offering is the offering of a security immediately upon effectiveness of the
registration statement. A “continuous” offering is one in which the issuer sells
securities over an extended period of time. A “delayed” offering is one in which the
issuer registers securities, but does not sell those securities until it subsequently does

Mr. Larry Greene

February 18, 2010

Page 3

    a “take down” of the securities being offered. An offering may involve one or more of
these elements, for example, a delayed, continuous offering would be a continuous offering
that occurred after the securities had been taken down from the shelf.

    Upon effectiveness of the Fund’s post-effective amendment no. 2, or the effectiveness of a
subsequent post-effective amendment, the Fund intends to resume its continuous
at-the-market offering of its common stock, for such periods during which sales are
permitted by Section 23(b) of the Investment Company Act of 1940, in accordance with the
principles articulated in Nuveen Virginia Premium Income Municipal Fund (pub. avail. Oct.
6, 2006). This offering is detailed in the form of prospectus supplement that was filed as
a part of post-effective amendment no. 2. In addition, the Fund has registered securities
for a delayed offering in which it may “take down” securities to sell at a date subsequent
to the effectiveness of post-effective amendment no. 2, or a subsequent post-effective
amendment, also in accordance with the principles articulated in Nuveen Virginia Premium
Income Municipal Fund (pub. avail. Oct. 6, 2006). Also, the Fund reserves the right to do
an immediate take-down from the securities registered for the shelf, which depending on the
circumstances, could be deemed to be an immediate offering.

    As can be seen from this discussion, these methods are complementary are not mutually
exclusive.

    6.

    Comment: On page 1 of the prospectus, the Fund notes that it “paid a one time arrangement fee
of .25% of the total borrowing limit” of its committed facility agreement with BNP Paribas.
Please explain supplementally whether this fee is recurring, or is truly a one-time fee.

    Response: We supplementally confirm that the arrangement fee paid by the Fund in connection
with its committed facility agreement with BNP Paribas was a one-time fee and is not
recurring.

    7.

    Comment: On page 1-2 of the prospectus, and again on pages 56-57 of the prospectus, the Fund
indicates that it has engaged in a Committed Facility Agreement with BNP Paribas Prime
Brokerage, Inc. (“BNP”). The Fund states that pursuant to this agreement, “BNP has the
ability to reregister the collateral in its own name or in another name other than the Fund to
pledge, re-pledge, sell, lend or otherwise transfer or use the collateral (“Hypothecated
Securities”) with all attendant rights of ownership.” Please provide the staff with a
supplemental explanation as to why it believes this arrangement is permissible under Section
17(f) of the 1940 Act.

    Response: The Fund believes that his arrangement meets the elements that the staff’s
previous guidance regarding permissible securities lending arrangements. The arrangement
with BNP involves a borrowing, which will be treated by the Fund as a senior security under
the provisions of Section 18 of the 1940 Act, along with a side

Mr. Larry Greene

February 18, 2010

Page 4

    agreement that creates a securities lending arrangement between the Fund and BNP. The Fund
has structured this securities lending arrangement to comply with various interpretive
letter that the SEC staff has issued over the years with respect to securities lending
arrangements. In particular, the Fund believes that this securities lending arrangement is
similar to that discussed in Morgan Guaranty Trust Co. of New York (pub. avail. Apr. 17,
1996). The Fund believes that the arrangement is permissible under the reasoning of that
letter, and other letters that the SEC’s staff has issued that permit securities lending
arrangements.

    After extensive discussions with the Division of Investment Management’s Office of Chief
Counsel, the Fund has agreed to provide the following disclosure of its arrangement with
BNP in its registration statement. This disclosure will replace similar disclosure
regarding the arrangements with BNP that is currently contained in the Fund’s prospectus.

    The Fund, with the approval of its Board of Trustees, including its independent
Trustees, has entered into a financing package that includes a Committed Facility
Agreement (the “Agreement”) with BNP Paribas Prime Brokerage, Inc. (as successor to
Bank of America N.A.) (“BNP”) that allows the Fund to borrow up to an initial limit
of $59,000,000, and a Lending Agreement, as defined below. The Agreement with BNP
replaced the existing extendible senior secured notes, and an initial draw-down of
$59,000,000 under the Agreement was utilized to pay off outstanding indebtedness
under the extendible senior secured notes in their entirety. Borrowings under the
Agreement are secured by assets of the Fund that are held with the Fund’s custodian
in a separate account (the “pledged collateral”). Interest is charged at the
quarterly LIBOR (London Inter-bank Offered Rate) plus 0.95% on the amount borrowed
and 0.85% on the undrawn balance. For the year ended October 31, 2009, the average
borrowings under the Agreement and the average interest rate were $30,263,014 and
1.98%, respectively. As of October 31, 2009, the amount of such outstanding
borrowings is $30,000,000. The interest rate applicable to the borrowings on
October 31, 2009 was 1.23%.

    The Lending Agreement is a separate side-agreement between the Fund and BNP
pursuant to which BNP may borrow a portion of the pledged collateral (the “Lent
Securities”) in an amount not to exceed the outstanding borrowings owed by the Fund
to BNP under the Agreement. The Lending Agreement is intended to permit the Fund
to significantly reduce the cost of its borrowings under the Agreement. BNP may
re-register the Lent Securities in its own name or in another name other than the
Fund, and may pledge, re-pledge, sell, lend or otherwise transfer or use the Lent
Securities with all attendant rights of ownership. The Fund may designate any
security within the pledged collateral as ineligible to be a Lent Security,
provided there are eligible

Mr. Larry Greene

February 18, 2010

Page 5

    securities within the pledged collateral in an amount equal to the outstanding
borrowing owed by the Fund. During the period in which the Lent Securities are
outstanding, BNP must remit payment to the Fund equal to the amount of all
dividends, interest or other distributions earned or made by the Lent Securities.
BNP will pay to the Fund a fee for borrowing the securities that is calculated as a
percentage of the difference between a fair market rate and a reference rate, with
a guaranteed minimum annualized rate.

    Under the terms of the Lending Agreement, the Lent Securities are marked to market
daily, and if the value of the Lent Securities exceeds the value of the
then-outstanding borrowings owed by the Fund to BNP under the Agreement (the
“Current Borrowings”), BNP must, on that day, either (1) return Lent Securities to
the Fund’s custodian in an amount sufficient to cause the value of the outstanding
Lent Securities to equal the Current Borrowings; or (2) post cash collateral with
the Fund’s custodian equal to the difference between the value of the Lent
Securities and the value of the Current Borrowings. If BNP fails to perform either
of these actions as required, the Fund will recall securities, as discussed below,
in an amount sufficient to cause the value of the outstanding Lent Securities to
equal the Current Borrowings. The Fund can recall any of the Lent Securities and
BNP shall, to the extent commercially possible, return such security or equivalent
security to the Fund’s custodian no later than three business days after such
request. If the Fund recalls a Lent Security pursuant to the Lending Agreement, and
BNP fails to return the Lent Securities or equivalent securities in a timely
fashion, BNP shall remain liable to the Fund’s custodian for the ultimate delivery
of such Lent Securities, or equivalent securities, and for any buy-in costs that
the executing broker for the sales transaction may impose with respect to the
failure to deliver. The Fund also has the right to apply and set-off an amount
equal to one hundred percent (100%) of the then-current fair market value of such
Lent Securities against the Current Borrowings. In addition, the Fund is a
beneficiary of an irrevocable guaranty issued by BNP’s parent, BNP Paribas, a
French banking institution that meets the definition of “eligible foreign
custodian” under Rule 17f-5 of the Investment Company Act of 1940. Under the terms
of the guaranty, BNP Paribas has agreed to guarantee the obligation of BNP to pay
to the Fund any cash or securities owed under the terms of the Lending Agreement.
The guaranty does not create any rights or grant any remedies to any person other
than the Fund and other persons who are defined as beneficiaries under the
guaranty. The Fund will exercise its set-off rights, or will exercise its rights
under the guaranty, when in accordance with its business discretion, it believes
that doing so is in the best interests of the Fund and its shareholders. The
Fund’s board of Trustees, including its independent Trustees, has determined that
the financing package is in the best interest of the Fund.

Mr. Larry Greene

February 18, 2010

Page 6

    8.

    Comment: On page 2 of the prospectus the Fund discusses Dividends and Distributions on Common
Shares. Please advise the staff supplementally whether the regular monthly dividends include
any return of capital to shareholders. In addition, please clarify the first paragraph to
note explicitly, if correct, that there were two dividends paid in January 2006 and January
2009: the regular monthly dividend and a second, special dividend.

    Response: The Fund has paid monthly distributions during the current fiscal year that were
estimated to be sourced, in part, from a return of capital, which is disclosed to
shareholders on the notice delivered in accordance with Section 19(a) of the 1940 Act.
However, distributions are subject to re-characterization for tax purposes after the end of
the fiscal year, and none of the Fund’s distributions have included a return of capital as
determined on a tax basis.

    The first paragraph of the section entitled “Dividends and Distributions on Common Shares”
on page 2 of the prospectus has been revised as follows:

    The Fund made special supplemental distributions, in addition to the
regular monthly distributions, of $0.0250 in January 2006 and of $0.0561 in
January 2009.

    9.

    Comment: In the last paragraph on page 2 of the prospectus, the Fund notes that it may pay a
portion of the dividends as a return of capital. Please advise the staff supplementally
whether there are any limits imposed on the ability of the Fund to make distributions of
capital.

    Response: As stated in the prospectus, the Fund currently intends to make monthly
distributions to common shareholders at a level rate established by the Board of Trustees.
Although there is technically no limit on the portion of those distributions that may be
sourced from a return of capital, the Fund first looks to net investment income and net
realized short-term capital gains to maintain a level distribution rate. To date, the Fund
has not “returned capital” as determined on a tax basis during any calendar year.

    10.

    Comment: The last sentence of the first full paragraph on page 4 of the prospectus (“In
addition, it is not contemplated....”) appears to indicate that the level distribution policy will
continue unchanged if the Fund

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    K&L Gates llp

    1601 K Street NW

    Washington, DC 20006-1600

    T 202.778.9000         www.klgates.com

September 1, 2009

Eric S. Purple

D 202.778.9220

F 202.778-9100

eric.purple@klgates.com

By E-mail and EDGAR

Mr. Larry Greene

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E., Room 4700

Washington, D.C. 20549

Attn: Mr. Larry Greene

    Re:

     Calamos Global Total Return Fund (File Nos. 333-146944 and 811-21547) Registration
 Statement
on Form N-2 Relating to Universal Shelf Offering

Dear Mr. Greene:

     On August 21, 2009, Calamos Global Total Return Fund (the “Fund”) filed Post-Effective
Amendment No. 2 to its Registration Statement on Form N-2 (the “Amendment”) for the purpose of: (1)
providing updated financial information and (2) making conforming language changes in response to
the Commission staff’s comments on substantially identical disclosure contained in the Registration
Statements for certain related funds, as described below. The purpose of this letter is to request
selective review of the Amendment, in accordance with the Commission’s release on selective review,
Revised Procedures For Processing Registration Statements, Post-Effective Amendments and
Preliminary Proxy Materials Filed by Registered Investment Companies, Investment Company Act
Release No. 13768 (February 15, 1984).

     In connection with the Fund’s 2008 universal shelf registration of Common Shares, Preferred
Shares and Debt Securities, the SEC staff reviewed the Fund’s prospectus, forms of prospectus
supplement and statement of additional information. The Fund is requesting selective review of
those portions of the Amendment that are identical to (or substantially identical to) the
registration statement previously filed for the purpose of registering its common shares of
beneficial interest (“Common Shares”), preferred shares of beneficial interest (“Preferred
Shares”), debt securities (“Debt Securities”), or any combination of Common Shares, Preferred
Shares or Debt Securities,
with a proposed maximum aggregate offering price of $75,000,000 (the “Shelf Registration
Statement”), which was declared effective in March 2008.

     In addition, much of the disclosure relating to the description of securities and plan of
distribution is substantially identical to disclosure in recent universal shelf registration
statements or amendments thereto (the “Other Calamos Fund Registration Statements”) relating to
common shares of beneficial interest, preferred shares of beneficial interest and debt securities
filed by:

Division of Investment Management

September 1, 2009

Page 2

    •

    Calamos Convertible Opportunities and Income Fund (File Nos. 333-146945 and
811-21080) (“CHI”);

    •

    Calamos Convertible and High Income Fund (File Nos. 333-146947 and 811-21319)
(“CHY”);

    •

    Calamos Global Dynamic Income Fund (File Nos. 333-153443 and 811-22047) (“CHW”); and

    •

    Calamos Strategic Total Return Fund (File Nos. 333-146943 and 811-21484) (“CSQ” and
together with CHI, CHY and CHW, the “Other Calamos Funds”).

     The Other Calamos Funds are closed-end investment companies managed by Calamos Advisors LLC,
the investment adviser of the Fund. After the Commission staff provided comments and reviewed the
responses to those comments, the Commission declared the Post-Effective Amendments to each of CHI’s
and CHY’s Registration Statements effective in April 2009. The Commission also previously declared
the CSQ Registration Statement effective in March 2008, after several rounds of comment letters and
responses. In addition, the Commission staff has reviewed the CHW Registration Statement and
provided comments in January 2009, March 2009 and August 2009. The Fund is requesting selective
review of those portions of the Shelf Registration Statement that are identical to (or
substantially identical to) the Other Calamos Fund Registration Statements, and therefore have been
subject to review by the Commission staff.

     As we have discussed, overall, the only substantive differences between the Amendment and the
Shelf Registration Statement and Other Calamos Fund Registration Statements, as appropriate, are:

    •

    the Amendment reflects the redemption of all of the Fund’s outstanding Auction Rate
Cumulative Preferred Shares (“ARPS”), and, as such, does not include the ARPS-specific
disclosure changes requested by the Commission staff during its review of the Other
Calamos Fund Registration Statements; and

    •

    the Amendment describes the terms of the Committed Facility Agreement with BNP
Paribas Prime Brokerage, Inc. (as successor to Bank of America N.A.) that allows the
Fund to borrow up to an initial limit of $59,000,000.

     Other than as described above, the description of securities and the plan of distribution
disclosed in the Amendment are substantially identical to the same portions of the Shelf
Registration Statement and Other Calamos Fund Registration Statements.

     In the paragraphs that follow, I have indicated the specific sections of the Shelf
Registration Statement with respect to which the Fund is requesting selective review.

Division of Investment Management

September 1, 2009

Page 3

     Please note that I have not indicated in the description below all places where changes were
made to update dates or other information, to reflect the fact that the Fund no longer has ARPS
outstanding, or other changes of a minor or conforming nature.

Prospectus

     Cover Page —The disclosure on the cover page is substantially identical to the
corresponding disclosure in the same location for the Other Calamos Funds.

     Prospectus Summary — I have listed below those subsections of the section captioned
“Prospectus Summary” that are substantially identical to disclosure previously subject to review by
the Commmission staff, and for which the Fund is requesting selective review.

     The Fund; Investment Adviser; The Offering; Use of Proceeds; and Dividends and Distributions
on Common Shares. The disclosure in these subsections is substantially identical to the
corresponding disclosure in the Other Calamos Funds’ Registration Statements.

     Investment Policies. The disclosure in these subsections is substantially identical to the
corresponding disclosure in the Shelf Registration Statement.

     Use of Leverage by the Fund; Interest Rate Transactions; and Conflicts of Interest. The
disclosure in this subsection is substantially identical to the corresponding disclosure in the
Other Calamos Funds’ Registration Statements.

     Fund Risks. The disclosure in this subsection is substantially identical to the disclosure in
the corresponding subsections of the Shelf Registration Statement and the Other Calamos Funds’
Registration Statements.

     Additional Risks to Common Shareholders; and Additional Risks to Senior Security Holders. The
disclosure in this subsection is substantially identical to the corresponding disclosure in the
Other Calamos Funds’ Registration Statements.

     Summary of Fund Expenses; Financial Highlights; Market and Net Asset Value Information;
and Use of Proceeds — The disclosure in these sections (aside from specific financial data) is
substantially identical to the corresponding sections of the Other Calamos Funds’ Registration
Statements.

     The Fund; and Investment Objective and Strategies — The disclosure in these sections
is substantially identical to the corresponding sections of the Shelf Registration Statement,
except for
the disclosure under the subsection “Conflicts of Interest”, which is substantially identical
to the corresponding subsection of the Other Calamos Funds’ Registration Statements.

     Leverage; and Interest Rate Transactions — The disclosure in these sections is
substantially identical to the corresponding sections of the Other Calamos Funds’ Registration
Statements.

Division of Investment Management

September 1, 2009

Page 4

     Risk Factors — The disclosure in this subsection is substantially identical to the
disclosure in the corresponding subsections of the Shelf Registration Statement and the Other
Calamos Funds’ Registration Statements, except for the disclosure under the subsections “Additional
Risks to Common Shareholders” and “Additional Risks to Senior Security Holders”, which is
substantially identical to the corresponding subsection of the Other Calamos Funds’ Registration
Statements.

     Management of the Fund — This section is substantially identical to the corresponding
sections of the Shelf Registration Statement and the Other Calamos Funds’Registration Statements.

     Closed-End Fund Structure; Certain Federal Income Tax Matters; Net Asset Value; Dividends
and Distributions on Common Shares; Automatic Dividend Reinvestment Plan; Description of
Securities; Rating Agency Guidelines; Plan of Distribution; Legal Matters; Experts; and Table of
Contents of Statement of Additional Information — The disclosure in these sections is
substantially identical to disclosure in the corresponding sections of the Other Calamos Funds’
Registration Statements. Please note that, as discussed, there is new disclosure in the
Description of Securities section that describes the describes the terms of the Committed Facility
Agreement with BNP Paribas Prime Brokerage, Inc.

     Certain Provisions of the Agreement and Declaration of Trust and By-Laws, Including
Antitakeover Provisions; Custodian, Transfer Agent, Dividend Disbursing Agent and Registrar; and
Available Information — The disclosure in these sections is substantially identical to
disclosure in the corresponding sections of the Shelf Registration Statement and the Other Calamos
Funds’ Registration Statements.

     Form of Prospectus Supplements — The forms of prospectus supplements included in the
Amendment are substantially identical to the corresponding sections in the Other Calamos Funds’
Registration Statements.

Prospectus Supplement Relating to Common Shares

     Cover Page —The disclosure on the cover page is substantially identical to the
corresponding disclosure in the same location for the Other Calamos Funds.

     Prospectus Supplement Summary — I have listed below those subsections of the section
captioned “Prospectus Supplement Summary” that are substantially identical to disclosure previously
subject to review by the Commission staff, and for which the Fund is requesting selective review.

     The Fund; Investment Adviser; The Offering; and Use of Proceeds. The disclosure in these
subsections is substantially identical to the corresponding disclosure in the Other Calamos Funds’
Registration Statements.

     Capitalization; Financial Highlights; Summary of Fund Expenses; Market and Net Asset Value
Information; Use of Proceeds; Plan of Distribution; Legal Matters; Experts; and Available

Division of Investment Management

September 1, 2009

Page 5

Information — The disclosure in these sections (aside from specific financial data) is
substantially identical to the corresponding sections of the Other Calamos Funds’ Registration
Statements.

Statement of Additional Information

     The disclosure in the Statement of Additional Information included in the Amendment is
substantially identical to the disclosure in the statement of additional information included in
the Other Calamos Funds’ Registration Statements, except for the disclosure in the “Investment
Objective and Policies” section, which is substantially identical to the corresponding disclosure
in the Shelf Registration Statement.

     Appendix A of the Statement of Additional Information (“Description of Ratings”) is
substantially identical to Appendix C of the statement of additional information included in the
Shelf Registration Statement, and Appendix B of the statement of additional information included in
the Other Calamos Funds’ Registration Statements.

     Please call me or David P. Glatz (312-807-4295) if you have any questions about the enclosed,
or if you require anything further.

Very truly yours,

Eric S. Purple

Enclosures

    cc:

    Stathy Darcy

    Paulita A. Pike

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ROBERT W. DIXON

312-609-7742

rdixon@vedderprice.com

March 7, 2008

VIA E-MAIL AND EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

Attn: Mr. Larry L. Greene, Senior Counsel

    Re:

    Calamos Strategic Total Return Fund

    File Nos. 333-146943 and 811-21484

    Calamos Convertible Opportunities and Income Fund

    File Nos. 333-146945 and 811-21080

    Calamos Convertible and High Income Fund

    File Nos. 333-146947 and 811-21319

    Calamos Global Total Return Fund

    File Nos. 333-146944 and 811-21547

To the Commission:

     On behalf of the above-referenced funds (each, a “Fund” and together, the “Funds”) and
pursuant to the Securities Act of 1933 and the Investment Company Act of 1940, Pre-Effective
Amendment No. 3 to each Fund’s Registration Statement on Form N-2 relating to the offering by each
Fund of common, preferred or debt securities in one or more offerings on an immediate, continuous or delayed basis (each, an “Amendment” and together, the “Amendments”) was filed on
March 7, 2008 with the Securities and Exchange Commission (the “Commission”).

     The Funds received oral comments on Pre-Effective Amendment No. 2 to each of the Registration
Statements as filed with the Commission on February 22, 2008 in a telephone conference between the
undersigned and Mr. Larry L. Greene of the Commission staff on February 26, 2008. We responded to
those oral comments in a letter from Ms. Deborah Eades to the Commission dated February 28, 2008.
The Funds then received additional oral comments on the responses contained in the February 28
letter in telephone conferences between the undersigned and Mr. Greene on March 4 and 6, 2008. The
purpose of the Amendments is to address the staff’s most recent comments. Those comments and the
Funds’ responses thereto are set forth below.

United States Securities and Exchange Commission

March 7, 2008

Page 2

     Please note that the Funds are concurrently submitting a request for acceleration of
effectiveness of the Registration Statements under separate cover.

     1.     Comment: Global Total Return Fund defines a “foreign issuer” as a foreign government or a
company organized under the laws of a foreign country. Please add disclosure following this
definition that describes the factors that Calamos considers in analyzing a foreign issuer’s
economic ties to a foreign country.

             Response: In response to the staff’s comment, Global Total Return Fund has added the
following disclosure to the prospectus summary under the caption “Investment Policies — Foreign
Securities” and in the body of the prospectus under the caption “Investment Objectives and
Principal Investment Strategies — Principal Investment Strategies — Foreign Securities”:

“In analyzing the foreign issuers in which the Fund may invest,
Calamos will generally consider a number of factors that may
characterize the issuer’s economic ties to a particular foreign
country or region. Such factors may include any or all of the
following: the characteristics of the economy in the principal
country or countries in which the issuer sells it goods and/or
services; the stability of the currency in the issuer’s country of
organization; the laws with respect to international trade and
property rights in the issuer’s country of organization; and the
tax, accounting and regulatory requirements of the issuer’s country
of organization.”

     2.     Comment: Please supplement the auction rate risk disclosure in “Leverage Risk” section
(applicable to common shareholders) of the Funds’ prospectuses to discuss the potential impact that
a maximum rate triggered in the event of a failed auction could have on common shareholders.

             Response: In response to the staff’s comment, the Funds have added the following disclosure
to the prospectuses under the caption “Risk Factors — Additional Risks to Common Shareholders —
Leverage Risk”:

“When a failed auction occurs, the dividend rate for the Fund’s
auction rate preferred shares is set at the maximum rate as
determined by the terms of such securities. In summary, the maximum
rate that goes into effect in the event of a failed auction is
determined by a formula equal to the applicable percentage of a
reference rate, which percentage ranges from 150% to 275%, depending
upon the rating then assigned to the preferred shares. The
reference rate is LIBOR for dividend periods of less than 365

United States Securities and Exchange Commission

March 7, 2008

Page 3

days,
and a U.S. Treasury average index rate for dividend periods of more
than 365 days. These reference rates, and thus the maximum rate,
can fluctuate over time. The formula for determining the maximum
rate will be described in more detail in an applicable prospectus
supplement if the Fund issues senior securities pursuant to this
registration statement.”1

     3.     Comment: Please supplementally describe to the staff the extent to which the Funds’ Board of
Trustees monitors the ongoing costs of the Funds’ outstanding leverage and the mechanisms at the
Funds’ disposal for reducing the amount of outstanding leverage, if necessary, in response to
increased leverage costs.

             Response: The Funds’ Board of Trustees monitors the cost of each Fund’s outstanding leverage
and the impact of the outstanding leverage on common shareholders on a regular and ongoing basis
through its quarterly reviews of the Funds’ financial performance and the Funds’ annual advisory
contract review process. As part of this ongoing review, the Board considers the options available
to the Funds to adjust amount of outstanding leverage, including the redemption of the Funds’
outstanding auction rate preferred shares, the tender or purchase of preferred shares and the
resale of any shares so tendered or purchased. These options are summarized in each Fund’s base
prospectus and are described in detail in the terms of the Funds’ preferred shares that are
attached as Appendix A to each Fund’s Statement of Additional Information.

* * * *

     If you have any questions or comments, please contact the undersigned at (312) 609-7742.

    Sincerely,

    /s/ Robert W. Dixon

    Robert W. Dixon

RWD/tas

1 Please note that the reference rate described above applies only with respect to Global Total
Return Fund and Strategic Total Return Fund, as stated in the Amendments for these two funds. The
reference rate with respect to Convertible Opportunities and Income Fund and Convertible and High
Income Fund is the “AA’ Financial Commercial Paper Rate,’’ as stated in the Amendments for these
two funds.

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March 7, 2008

VIA E-MAIL AND EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attention: Mr. Larry L. Greene

    Re:

    Calamos Strategic Total Return Fund

    File Nos. 333-146943 and 811-21484

    Calamos Convertible Opportunities and Income Fund

    File Nos. 333-146945 and 811-21080

    Calamos Convertible and High Income Fund

    File Nos. 333-146947 and 811-21319

    Calamos Global Total Return Fund

    File Nos. 333-146944 and 811-21547

Ladies and Gentlemen:

     Pursuant to Rule 461 under the Securities Act of 1933, the above referenced funds (the
“Registrants”) hereby request that the effective date of the Registration Statements referred to
above be accelerated so that they will be declared effective on
March 10, 2008, or as soon as
possible thereafter, after notification by telephone to the staff that the Registration Statements
are correct and complete with the exception of information omitted in reliance upon Rule 430A,
which will be provided in a final prospectus or prospectus supplement at the time of offering.
Future managing or principal underwriters of a particular offering pursuant to the Registration
Statements, if any, will be identified in prospectus supplements to the Registration Statements at
the time of offering.

     With respect to the Registrants’ request for acceleration of the effective date of the
Registration Statements, please be advised that the Registrants acknowledge that:

     (1) the Registrants are responsible for the adequacy and accuracy of the disclosure in the
filings;

     (2) should the Commission or the staff, acting pursuant to delegated authority, declare the
filings effective, it does not foreclose the Commission from taking any action with respect to the
filings;

     (3) the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filings effective, does not relieve the Registrants from their full responsibility
for the adequacy and accuracy of the disclosure in the filings; and

     (4) the Registrants may not assert this action as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

    Very truly yours,

    /s/ Nimish S. Bhatt

    Nimish S. Bhatt

    Vice President and Chief Financial Officer

On Behalf of the Registrants Listed Above

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DEBORAH BIELICKE EADES

312-609-7661

deades@vedderprice.com

VEDDER, PRICE P.C.

222 NORTH LASALLE STREET

CHICAGO, ILLINOIS 60601

312-609-7500

FAX: 312-609-5005

CHICAGO
• NEW YORK CITY • WASHINGTON, D.C. • ROSELAND, NJ

February 28, 2008

VIA E-MAIL AND EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

Attn: Mr. Larry L. Greene, Senior Counsel

    Re:

    Calamos Strategic Total Return Fund

File Nos. 333-146943 and 811-21484

Calamos Convertible Opportunities and Income Fund

File Nos. 333-146945 and 811-21080

Calamos Convertible and High Income Fund

File Nos. 333-146947 and 811-21319

Calamos Global Total Return Fund

File Nos. 333-146944 and 811-21547

To the Commission:

     On behalf of the above-referenced funds (each, a “Fund” and together, the “Funds”) and
pursuant to the Securities Act of 1933 (“1933 Act”) and the Investment Company Act of 1940 (“1940
Act”), Pre-Effective Amendment No. 3 to each Fund’s Registration Statement on Form N-2 relating to
the offering by each Fund of common, preferred or debt securities in one or more offerings on an
immediate, continuous or delayed basis (each, an “Amendment” and together, the “Amendments”) will
be filed on or about February 28, 2008 with the Securities and Exchange Commission (the
“Commission”). The purpose of the Amendments is to respond to comments received from the
Commission staff and to complete certain information required by Form N-2.

     The Funds received oral comments on Pre-Effective Amendment No. 2 to each of the Registration
Statements as filed with the Commission on February 22, 2008 in a telephone conference between
Robert Dixon of Vedder Price P.C. and Mr. Larry L. Greene of the
Commission staff on February 26, 2008. The following sets forth those comments and the Funds’
responses thereto.

VedderPrice

United States Securities and Exchange Commission

February 28, 2008

Page 2

1. Comment: Global Total Return Fund defines a “foreign issuer” as a foreign government or a
company organized under the laws of a foreign country. Explain to the staff how a foreign issuer
being organized under the laws of a foreign country demonstrates that the issuer is economically
tied to that jurisdiction.

     Response: The Fund is a global fund and does not emphasize a particular geographic region.
The Fund believes that an issuer’s domicile outside the United States is an objective measure and a
strong indication that the issuer has significant ties outside the United States. Issuers
organized outside the United States have relatively little incentive to subject themselves to the
securities, tax and other laws of the United States. A foreign issuer organized under the laws of
a foreign country is subject to the currency, socio-economic and political risks of that
jurisdiction, including nationalization. Issuers located outside the United States are subject to
tax, accounting and regulatory requirements of its place of domicile and any additional
jurisdictions or exchanges in which its securities are sold or traded. Accordingly, the Fund
believes that issuers organized outside the United States are likely to have significant economic,
and other, ties outside the United States.

2. Comment: With respect to the fee table in the Funds’ prospectuses, explain to the staff for
which Funds the adviser contractually waives a portion of its fees.

     Response: With respect to each of Convertible Opportunities and Income Fund and Convertible
and High Income Fund, Calamos has contractually agreed to waive a portion of its management fee.
The contractual fee waiver is reflected as a line item in the fee table for each Fund and is
further explained in footnote 5 to the fee table. There are no contractual fee waiver arrangements
in place for either Strategic Total Return Fund or Global Total Return Fund, and, accordingly, no
line item in the fee table or corresponding footnote has been included in the “Summary of Fund
Expenses” section of the Fund’s prospectus.

3. Comment: Please supplement the auction rate risk disclosure in the prospectuses for the Funds
to discuss the risks associated with, and potential results of, auction failure and that common
shareholders bear the risk of increased leverage costs resulting from a failed auction.

     Response: The following disclosure has been added to the “Auction Risk” section of each
prospectus (applicable to preferred shareholders):

The markets for auction rate securities have continued to face widening spreads,
reduced demand and, more recently, an increased number of failed auctions. A failed
auction results when there are not enough bidders in the auction at rates below the
maximum rate as prescribed by the terms of the security. When an
auction fails, all holders receive the maximum rate and may be unable to sell their
shares until the next auction, which may be for an indefinite period of time.

VedderPrice

United States Securities and Exchange Commission

February 28, 2008

Page 3

     The following disclosure has been added to the “Leverage Risk” section of the prospectus
(applicable to common shareholders):

The markets for auction rate securities have continued to face widening spreads,
reduced demand and, more recently, an increased number of failed auctions. These
conditions may result in higher leverage costs to common shareholders.

*           *           *

     If you have any questions or comments, please contact the undersigned at (312) 609-7661.

    Sincerely,

                                   /s/ Deborah Bielicke Eades

    Deborah Bielicke Eades

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February 22, 2008

VIA E-MAIL AND EDGAR

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549

Attention: Mr. Larry L. Greene

         Re:

    Calamos Strategic Total Return Fund

File Nos. 333-146943 and 811-21484

Calamos Convertible Opportunities and Income Fund

File Nos. 333-146945 and 811-21080

Calamos Convertible and High Income Fund

File Nos. 333-146947 and 811-21319

Calamos Global Total Return Fund

File Nos. 333-146944 and 811-21547

Ladies and Gentlemen:

     Pursuant to Rule 461 under the Securities Act of 1933, the above referenced funds (the
“Registrants”) hereby request that the effective date of the Registration Statements referred to
above be accelerated so that they will be declared effective on
February 26, 2008, or as soon as
possible thereafter, after notification by telephone to the staff that the Registration Statements
are correct and complete with the exception of information omitted in reliance upon Rule 430A,
which will be provided in a final prospectus or prospectus supplement at the time of offering.
Future managing or principal underwriters of a particular offering pursuant to the Registration
Statements, if any, will be identified in prospectus supplements to the Registration Statements at
the time of offering.

     With respect to the Registrants’ request for acceleration of the effective date of the
Registration Statements, please be advised that the Registrants acknowledge that:

     (1) the Registrants are responsible for the adequacy and accuracy of the disclosure in the
filings;

     (2) should the Commission or the staff, acting pursuant to delegated authority, declare the
filings effective, it does not foreclose the Commission from taking any action with respect to the
filings;

     (3) the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filings effective, does not relieve the Registrants from their full responsibility
for the adequacy and accuracy of the disclosure in the filings; and

     (4) the Registrants may not assert this action as a defense in any proceeding initiated by the
Commission or any person under the federal securities laws of the United States.

    Very truly yours,

    /s/ Nimish S. Bhatt

    Nimish S. Bhatt

    Vice President and Chief Financial Officer

On Behalf of the Registrants Listed Above

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ROBERT W. DIXON

312-609-7742

rdixon@vedderprice.com

February 22, 2008

VIA E-MAIL AND EDGAR

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

Attn: Mr. Larry L. Greene, Senior Counsel

         Re:

    Calamos Strategic Total Return Fund

File Nos. 333-146943 and 811-21484

Calamos Convertible Opportunities and Income Fund

File Nos. 333-146945 and 811-21080

Calamos Convertible and High Income Fund

File Nos. 333-146947 and 811-21319

Calamos Global Total Return Fund

File Nos. 333-146944 and 811-21547

To the Commission:

     On behalf of the above-referenced funds (each, a “Fund” and together, the “Funds”) and
pursuant to the Securities Act of 1933 (“1933 Act”) and the Investment Company Act of 1940 (“1940
Act”), Pre-Effective Amendment No. 2 to each Fund’s Registration Statement on Form N-2 relating to
the offering by each Fund of common, preferred or debt securities in one or more offerings on an
immediate, continuous or delayed basis (each, an “Amendment” and together, the “Amendments”) was
filed on February 22, 2008 with the Securities and Exchange Commission (the “Commission”). The
purpose of the Amendments is to respond to comments received from the Commission staff and to
complete certain information required by Form N-2.

     The Funds received oral comments on Pre-Effective Amendment No. 1 to each of the Registration
Statements as filed with the Commission on January 30, 2008 in a telephone conference between the
undersigned and Mr. Larry L. Greene of the Commission staff on February 14, 2008. The following
sets forth those comments and the Funds’ responses thereto.

     Please note that the Funds are concurrently submitting a request for acceleration of
effectiveness of the Registration Statements under separate cover.

United States Securities and Exchange Commission

February 22, 2008

Page 2

1. Comment: Please state whether the Funds meet the registrant and transaction eligibility
requirements of Form S-3 since the Funds are relying on Rule 415(a)(1)(x) to make the offerings
contemplated in the Registration Statements.

Response: Each of the Funds meets the registrant1 and transaction2
eligibility requirements of Form S-3 and, thus, is eligible to rely on Rule 415(a)(1)(x) to make
the offerings contemplated in the Registration Statements. With respect to registrant
requirements, (1) each Fund is organized in Delaware and has its principal business operations in
the United States, (2) each Fund’s common shares are registered pursuant to Section 12(b) of the
Exchange Act, (3) each Fund has been subject to Section 12 of the Exchange Act and the Investment
Company Act of 1940 for more than twelve months and has timely filed all reports required
thereunder over the last twelve months and up to the present, (4) none of the Funds has, since the
end of its last fiscal year, failed to pay any dividend or sinking fund installment on preferred
stock or defaulted on any installment on indebtedness for borrowed money and (5) each Fund has filed all required electronic
filings in accordance with Regulation S-T. With respect to the transaction requirements, all
offerings contemplated in Registration Statements will be for cash, and

    1

    Instruction I.A to Form S-3 requires, in relevant part,
that: (1) The registrant is organized under the laws of the United States or
any State or Territory or the District of Columbia and has its principal
business operations in the United States or its territories; (2) The registrant
has a class of securities registered pursuant to Section 12(b) of the
Securities Exchange Act of 1934 (“Exchange Act”) or a class of equity
securities registered pursuant to Section 12(g) of the Exchange Act or is
required to file reports pursuant to Section 15(d) of the Exchange Act; (3) The
registrant: (a) has been subject to the requirements of Section 12 or 15(d) of
the Exchange Act and has filed all the material required to be filed pursuant
to Sections 13, 14 or 15(d) for a period of at least twelve calendar months
immediately preceding the filing of the registration statement on this Form;
and (b) has filed in a timely manner all reports required to be filed during
the twelve calendar months and any portion of a month immediately preceding the
filing of the registration statement [other than certain Form 8-K reports]. If
the registrant has used (during the twelve calendar months and any portion of a
month immediately preceding the filing of the registration statement) Rule
12b-25(b) under the Exchange Act with respect to a report or a portion of a
report, that report or a portion thereof has actually been filed within the
time period prescribed by the Rule;...(5) Neither the registrant nor any of its
consolidated or unconsolidated subsidiaries have, since the end of the last
fiscal year for which certified financial statements of the registrant and its
consolidated subsidiaries were included in a report filed pursuant to Section
13(a) or 15(d) of the Exchange Act: (a) failed to pay any dividend or sinking
fund installment on preferred stock; or (b) defaulted (i) on an installment or
installments on indebtedness for borrowed money or (ii) on any rental on one or
more long term leases, which defaults in the aggregate are material to the
financial position of the registrant and its consolidated or unconsolidated
subsidiaries, taken as a whole;...and (8) Electronic Filings: In addition to
satisfying the foregoing conditions, a registrant subject to the electronic
filing requirements of Rule 101 of Regulation S-T (§232.101 of this chapter)
shall have filed with the Commission all required electronic filings, including
confirming electronic copies of documents submitted in paper pursuant to a
hardship exemption as provided by Rule 201 or Rule 202(d) of Regulation S-T
(§232.201 or §232.202(d) of this chapter).

    2

    Instruction I.B.1 of Form S-3 requires, in relevant
part, that the securities must be offered for cash by or on behalf of a
registrant and that the aggregate market value of the voting and non-voting
common equity held by non-affiliates of the registrant is $75 million or more.

United States Securities and Exchange Commission

February 22, 2008

Page 3

the aggregate market
value of each Fund’s common equity held by non-affiliates exceeds $75 million.

2. Comment: The first paragraph of disclosure captioned “Prospectus Summary — Distributions”
discusses distribution history. Each Fund discloses in the first sentence that it has made regular
distributions to its shareholders for a specified period. Please disclose whether any of the
Funds’ historical distributions have included a return of capital.

Response: In response to the staff’s comment, each Fund has included in its Amendment the
following sentence in the second paragraph following the caption “Prospectus Summary —
Dividends and Distributions on Common Shares”: “To date, however, none of the Fund’s
distributions have included a return of capital as determined on a tax basis during any
calendar year.”

3. Comment: Global Total Return Fund defines a “foreign issuer” as a foreign government or a
company organized under the laws of a foreign country. Under this definition, a company could be
incorporated in a foreign country, yet derive substantial revenue from, and have substantial assets
in, the U.S. Please either (a) revise this definition of “foreign issuer” to include a criterion
that establishes that an issuer is somehow economically tied to the country of its organization or
(b) revise the Fund’s risk disclosure to state that, even though a foreign issuer may be organized
in a foreign country, it may be subject to prevailing market conditions in the U.S.

Response: In response to the staff’s comment, Global Total Return Fund has included the
following disclosure in the Amendment under the caption “Fund Risks — Foreign Securities
Risk” in both the prospectus summary and in the body of the
prospectus under the caption “Risk
Factors”:

“Based upon the Fund’s test for determining whether an issuer is a
‘foreign issuer’ as described above, it is possible that an issuer
of securities in which the Fund invests could be organized under the
laws of a foreign country, yet still conduct a substantial portion
of its business in the U.S. or have substantial assets in the U.S.
In this case, such a ‘foreign issuer’ may be subject to the market
conditions in the U.S. to a greater extent than it may be subject to
the market conditions in the country of its organization.”

4. Comment: With respect to the example calculations for the 1, 3, 5, and 10 year periods
following the fee table, explain to the staff in which specific columns the adviser’s fee waivers
and reimbursements are reflected with respect to Convertible Opportunities and Income Fund and
Convertible and High Income Fund.

United States Securities and Exchange Commission

February 22, 2008

Page 4

     Response: With respect to Convertible Opportunities and Income Fund, because Calamos’
fee waiver extends through 2010 (as described in footnote 6), the fee waiver is assumed to
be in effect for all or a portion of the “1 year” and “3 years” columns of the expense
example. Because the hypothetical expense figures in each column are cumulative expense
totals, however, the figures shown in all of the columns also reflect the effect of the fee
waiver in that they include the Fund’s hypothetical expenses incurred through 2010. With
respect to Convertible and High Income Fund, because Calamos’ fee waiver extends through
2011 (as described in footnote 6), the fee waiver is assumed to be in effect for all or a
portion of the “1 year”, “3 years” and “5 years” columns of the expense example. Because
the hypothetical expense figures in each column are cumulative expense totals, however, the
figures shown in all of the columns also reflect the effect of the fee waiver in that they
include the Fund’s hypothetical expenses incurred through 2011.

5. Comment: Consistent with the Funds’ response to comment 15 set forth in the Funds’ letter to
the Commission dated January 30, 2008 (the “Response Letter”), include disclosure in the
prospectuses for the Global Total Return Fund and the Strategic Total Return Fund to reflect that
the Funds use the term “dynamic” to describe Calamos’ ability to manage the Funds’ portfolios over
different market cycles on a long-term basis, as opposed to engaging in an active turnover of
securities.

Response: The following changes have been made in the Amendment for Global Total Return
Fund in response to the staff’s comment: “Calamos will dynamically allocate the Fund’s
investments among multiple asset classes (rather than maintaining a fixed or static
allocation), seeking to obtain an appropriate balance of risk and reward on a long-term
basis through all market cycles using multiple strategies and combining them to seek to
achieve favorable risk adjusted returns.” (Emphasis added.)

The following changes have been made in the Amendment for Strategic Total Return Fund in
response to the staff’s comment: “Calamos will dynamically allocate the Fund’s investments
among multiple asset classes (rather than maintaining a fixed or static allocation),
seeking to obtain an appropriate balance of risk and reward on a long-term basis
through all market cycles using multiple strategies and combining them to seek to achieve
favorable risk adjusted returns.” (Emphasis added.)

6. Comment: Please confirm that the Funds’ response to comment 19 set forth in the Response Letter
regarding “REIT Risk” is still accurate in light of the continuing deterioration of U.S. credit
markets.

Response: The Funds confirm their view as set forth in the Response Letter that the
current problems associated with the sub-prime loan and mortgage markets primarily

United States Securities and Exchange Commission

February 22, 2008

Page 5

relate to
residential real estate, and not the commercial real estate that underlies the Funds’
investments in REITs. Accordingly, the Funds continue to believe that additional risk
disclosure regarding the Funds’ REIT investments is not necessary and further note that the
Funds’ present and anticipated investments in REIT securities are minimal.

7. Comment: Please supplement the following disclosure included in each Fund’s Pre-Effective
Amendment No. 1 in response to the Commission’s original comment 21 to state that the Funds’ Board
monitors any differing interests that may arise between Calamos and the Funds regarding the Funds’
use of leverage: “Consequently, the Fund and Calamos may have differing interests in determining
whether to leverage the Fund’s assets.”

Response: The Funds have added the
following disclosure after the
sentence quoted above in the
Amendments: “The Fund’s Board of
Trustees monitors any potential
conflicts of interest on an ongoing
basis.”

* * *

     If you have any questions or comments, please contact the undersigned at (312) 609-7742.

Sincerely,

Robert W. Dixon

RWD/tas

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ROBERT W. DIXON

312-609-7742

rdixon@vedderprice.com

January 30, 2008

United States Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, DC 20549

Attn: Mr. Larry L. Greene, Senior Counsel

    Re:

    Calamos Strategic Total Return Fund

File Nos. 333-146943; 811-21484

Calamos Convertible Opportunities and Income Fund

File Nos. 333-146945; 811-21080

Calamos Convertible and High Income Fund

File Nos. 333-146947; 811-21319

Calamos Global Total Return Fund

File Nos. 333-146944 and 811-21547

To the Commission:

     On behalf of the above-referenced funds (each, a “Fund” and together, the “Funds”) and
pursuant to the Securities Act of 1933 (“1933 Act”) and the Investment Company Act of 1940 (“1940
Act”), Pre-Effective Amendment No. 1 to each Fund’s Registration Statement on Form N-2 relating to
the offering by each Fund of common, preferred or debt securities in one or more offerings on an
immediate, continuous or delayed basis (each, an “Amendment” and together, the “Amendments”) was
filed on January 30, 2008 with the Securities and Exchange Commission (the “Commission”). The
purpose of the Amendments is to respond to comments received from the Commission staff and to
complete certain information required by Form N-2. A courtesy copy of each of the Amendments,
marked to show changes from the initial filings, will be sent to the Commission staff separately to
assist with its review.

     The Funds received comments on the Registration Statements as filed with the Commission by
letter from Mr. Larry L. Greene of the Commission staff dated December 5, 2007. The following sets
forth those comments and the Funds’ responses thereto.

United States Securities and Exchange Commission

January 30, 2008

Page 2

General

1. Comment: Please state in your response letter whether FINRA will or has reviewed the proposed
underwriting terms and arrangements of the transaction involved in the registration statement.

Response: In anticipation of one or more potential offerings of their common shares through
underwritten offerings, the Funds expect that relevant portions of the filings, with the
assistance of the underwriters and their counsel, will be submitted to the FINRA for review.
However, we note that if the securities to be offered are within the categories specified
in NASD Conduct Rule 2710(b)(7)(B), such review will not be necessary.

2. Comment: Explain to the staff whether the Funds will file post-effective amendments in order
to sell securities off the shelf or whether they propose to file supplements under Rule 497. If
the latter, advise the staff how the legal opinion and financial statements will be updated.

Response: The Funds expect to file both post-effective amendments pursuant to Rule 462(d)
and supplements pursuant to Rule 497 in connection with each offering. A legal opinion and
offering documents specific to each particular offering will be filed as an exhibit to each
post-effective amendment. In addition, the Funds will update financial statements on an
annual basis by filing post-effective amendments subject to the staff’s review. The Funds
may also file interim financial statements from time to time pursuant to Rule 497.

3. Comment: The pricing table on the facing page discloses the amount of securities being
registered. Confirm that securities to be used to fulfill any over-allotments will be included in
the amount being registered.

Response: The Funds confirm that securities to be used to fulfill any over-allotment
options of the underwriters will be included in the amounts being registered.

4. Comment: Please see the U.S. Securities and Exchange Commission, A Plain English Handbook
(1998). Please review and revise the disclosure where it appears necessary so as to assure
conformity with the Commission’s plain English requirements. For example, reformat disclosures
appearing in all capital letters on the cover of the Statement of Additional Information and
elsewhere in the document. Please use a different means to make the disclosure prominent (e.g.,
bold). Clarify the types of indices referred to in the following underlined clause: “The Fund may
also purchase and sell options on securities indices and other financial indices.”
(Emphasis added.) Clarify the meaning of the following disclosure: “Their discretionary target
bonus is set at a percentage of the respective base salary, ranging from 300% to 600%, with a
maximum annual bonus opportunity of 150% of the target bonus.” Last of all, confirm that the

United States Securities and Exchange Commission

January 30, 2008

Page 3

disclosure in the filing meets the type size requirements of Rule 420 of Regulation C under the
Securities Act.

Response: The Funds confirm that the referenced disclosure will not appear all-capitalized
in the final print. Additional changes responsive to the staff’s specific requests have
been made in the Amendments. The Funds also confirm that the disclosure in the filings is
in roman type at least as large as 10-point modern type, as required by Rule 420. The Funds
believe that the filings otherwise comply with the Commission’s plain English requirements.

5. Comment: We note that the Funds did not include cover letters with their registration
statements indicating the purpose of the filings. In the future, we suggest each Fund include
written correspondence with every filing indicating the name and the telephone number of the person
to be contacted for information regarding the submission, the purpose of the filing, and whether it
contains any novel or special issues, or disclosure, that warrant staff attention.

Response: The Funds have noted the staff’s comment and will include cover letters with
future filings.

6. Comment: The facing page indicates that each filing was made under Rule 415. Explain to the
staff the enumerated paragraph of the rule upon which the Funds are relying to make the offerings.

Response: The Funds are relying on Rule 415(a)(1)(x) to make the offerings contemplated in
the Registration Statements. In No-Action Letters issued to Pilgrim America Prime Rate
Trust and Nuveen Virginia Premium Income Municipal Fund,1 the staff indicated
that a closed-end investment company may rely on Rule 415(a)(1)(x) to issue securities
pursuant to a shelf registration statement provided that the issuer disseminates a “steady
stream of high quality information” about the issuer to the public. The Funds believe that
the information about the Funds regularly disseminated to the public satisfies the
Commission’s concern regarding the availability of a steady stream of high quality
information about the Funds. In reliance on the staff’s views set forth in the Pilgrim
letter, as modified by the Nuveen letter, the Funds believe that they are eligible to rely
on Rule 415(a)(1)(x) to make the offerings contemplated in the Registration Statements.

    1

    Pilgrim America Prime Rate Trust (publicly available
May 1, 1998); Nuveen Virginia Premium Income Municipal Fund (publicly available
October 6, 2006).

United States Securities and Exchange Commission

January 30, 2008

Page 4

Prospectus

7. Comment: Add the underlined clause to the following disclosure captioned “Cautionary Notice
Regarding Forward-Looking Statements”: “The forward-looking statements contained in this
prospectus and any accompanying prospectus supplement and the statement of additional
information are excluded from the safe harbor protection provided by section 27A of the
Securities Act of 1933, as amended (the ‘1933 Act’).”

Response: Changes responsive to the staff’s comment have been made in the Amendments.

8. Comment: The first paragraph of disclosure captioned “Prospectus Summary — Distributions”
discusses distribution history. Each Fund discloses in the first sentence that it has made regular
distributions to its shareholders for a specified period. Specify the nature of the distribution
(e.g., net investment income). The second sentence of this discussion in the Global Total Return
prospectus discloses that: “Additionally, the Fund has made periodic distributions of
long-term capital gains since inception.” (Emphasis added.) Confirm that such distributions
complied with §19(b) under the 1940 Act and Rule 19b-1 thereunder.

Response: In connection with each distribution to shareholders, Calamos issues a notice to
shareholders that describes, to the extent known at such time, the source of the
distribution, whether it be undistributed net investment income, undistributed net realized
short-term capital gains, capital or a combination thereof. The Funds note that these
various sources of distributions are described in the third sentence of the paragraph
immediately following the paragraph in question and respectfully believe that this existing
disclosure is responsive to the staff’s comment. In addition, the Global Total Return Fund
confirms that all long-term capital gain distributions made by the Fund since inception have
complied with §19(b) under the 1940 Act and Rule 19b-1 thereunder.

9. Comment: The second and third paragraphs under this caption discuss Global Total Return’s
current managed distribution policy and its efforts to obtain an SEC order to implement such a
plan. The disclosure regarding its current policy indicates, among other things, that
distributions may include net investment income, net realized short-term capital gain and, if
necessary, return of capital; and that at times it may pay out more or less than the entire amount
of income earned. Briefly state how the Fund expects the policy might change if the order is
granted. Provide disclosure that distinguishes managed distributions from true yield and disclose
any adverse tax implications of the Funds’ current policies.

     The same disclosure discusses the possibility that the Fund’s distributions may constitute
returns of capital and that: “To the extent the Fund distributes an amount in excess of the Fund’s
current and accumulated earnings and profits, such excess, if any, will be treated by a shareholder
for federal income tax purposes as a tax-free return of capital to the extent of the

United States Securities and Exchange Commission

January 30, 2008

Page 5

shareholder’s adjusted tax basis in his, her or its shares and thereafter as a gain from the
sale or exchange of such shares.” With respect to such distributions, provide additional
disclosure in the prospectus regarding i) the effect of a distribution on a shareholder’s basis,
and ii) if applicable, that a substantial amount of the distributions in any year will be a return
of capital.

Response: The Funds expect that the receipt of an SEC order granting the Funds the ability
to implement a managed distribution policy would enable the Funds to more effectively manage
distributions on a long-term basis by more frequently utilizing long-term gains as a
potential source of distributions. Absent receipt of the order, the Funds may distribute
net realized long-term capital gains only once annually, although a second distribution is
permitted to the extent necessary to avoid the imposition of an excise tax. The Funds
believe that a managed distribution policy that allows the Funds to utilize long-term
capital gains more frequently may enhance the tax efficiency of distributions to the Funds’
shareholders. In addition, in response to the staff’s requests, the Funds have added the
following disclosure to the Amendments for purposes of (i) describing the effect of a return
of capital distribution on a shareholder’s adjusted tax basis, and (ii) distinguishing
managed distributions from true yield.

“To the extent the Fund distributes an amount in excess of the
Fund’s current and accumulated earnings and profits, such excess, if
any, will be treated by a shareholder for federal income tax
purposes as a tax-free return of capital to the extent of the
shareholder’s adjusted tax basis in his, her or its shares and
thereafter as a gain from the sale or exchange of such shares.
Any such distributions made by the Fund will reduce the
shareholder’s adjusted tax basis in his, her or its shares to the
extent that the distribution constitutes a return of capital. To
the extent that the Fund’s distributions exceed the Fund’s current
and accumulated earnings and profits, the distribution payout rate
will exceed the yield generated from the Fund’s investments.”
(Emphasis added.)

The Funds believe that any adverse tax implications of the Funds’ current distribution
policies are currently disclosed in the sections captioned “Prospectus Summary —
Distributions” and “Certain Federal Income Tax Matters.” Finally, the Funds hereby
supplementally inform the staff that the Funds do not expect a substantial amount of
distributions in any year to constitute a return of capital.

10. Comment: Disclosure in the fourth paragraph states: “Since not all investors can
participate in the automatic dividend reinvestment plan, you should contact your broker or
nominee to confirm that you are eligible to participate in the plan.” (Emphasis added.) Explain
why some investors may not participate in the plan.

United States Securities and Exchange Commission

January 30, 2008

Page 6

Response: The Funds have revised the referenced sentence in the Amendments to read as
follows: “Since investors can participate in the automatic dividend reinvestment plan only
if their broker or nominee participates in our plan, you should contact your broker or
nominee to confirm that you are eligible to participate in the plan.”

11. Comment: The next sub-caption, “Investment Policies,” contains disclosure which states that:
“Under normal circumstances, the Fund will invest at least 30% of its managed assets in securities
of foreign issuers.” A foreign issuer is defined as a foreign government or a company organized
under the laws of a foreign country. Some companies are incorporated in a foreign country, yet
derive substantial revenue from, and have substantial assets in, the U.S. Will the Fund treat that
company as a foreign issuer? If yes, disclose that fact and how it affects the global nature of an
investment in the Fund.

Response: Under the Fund’s definition of a foreign issuer, a foreign issuer is a foreign
government or company organized under the laws of a foreign country, regardless of where it
conducts business, maintains its assets, provides services or where its securities are
principally traded. The Fund believes that this definition is appropriate for a “global”
fund that does not emphasize any particular country or region. The Fund also notes that
this definition of a foreign issuer is the same as the definition reviewed by the staff in
connection with the initial offering of common shares by Calamos Global Dynamic Income Fund
(File No. 333-142506).

12. Comment: The last paragraph under this sub-caption discloses that: “The Fund may invest in
other securities of various types to the extent consistent with its investment objective.” This
policy suggests the Fund may acquire whatever it wants whether or not disclosed in the prospectus.
Either delete this disclosure or explain its meaning to the staff.

Response: Each Fund generally expects to only invest in securities of the types described
in its respective prospectus and statement of additional information, to the extent
consistent with each Fund’s respective investment objective. The Funds have included the
disclosure cited above to address the possibility that, as financial markets evolve and new
types of investment products become available, the Funds may invest in these new investment
products, but only to the extent consistent with a Fund’s investment objective. The Funds
note that any material changes to a Fund’s investment objectives or the types of securities
in which a Funds may invest will be disclosed in that Fund’s annual and/or semi-annual
reports to shareholders, as

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C.20S49
DIVISION OF
INVESTMENT MANAGEMENT
Robert W. Dixon, Esq.
Vedder, Price, Kaufman & Kamolz, P.C.
222 Nort LaSalle Street
Chicago, llinois 60601-1003
Re: Calamos Strategic Total Return Fund
File Nos. 333-146943, 811-21484
Calamos Converible opportties and Income Fund
File Nos. 333-146945, 811-21080
Calamos Converble and High Income Fund
File Nos. 333-146947, 811-21319
Calamos Global Total Retu Fund
File Nos. 333-146944, 811-21547
(each a "Fund" and together, the "Funds")
Dear Mr. Dixon:
On October 26,2007, Calamos Strategic Total Retu Fund, Calamos Convertible
Opportnities and Income Fund ("Convertble Opportties"), Calamos Converible and
High Income Fund ("Convertble High Income"), and Calamos Global Total Retu Fund
("Global Total Return") each filed a registration statement on Form N-2 under the
Securties Act of 1933 ("Securties Act") and the Investment Company Act of 1940
("1946 Act"). .
The fiings are similar in many respects and each seeks to offer on an imediate,
continuous or delayed basis common, preferred, or debt securties in one or more
offerings. The filings also differ in certain respects, e.g., the tye and amount of
securties to be purchased. In light of the simlarty of the. filings, we focused our review
oif the filing made by Global Total Retu. We have combined our corrents regarding
! all four Funds in ths correspondence; accordingly, a comment on disclosure that is
substantially similar to information in any other filing applies to that other filing as well.
Where appropriate, we identified comments applicable to Funds other than Global Total
Retu.
We wil review each Fund's fiancial statements and other information submitted
in subsequent amendments and may have comments regarding that information. Our
comments regarding the filings are set forth below.
General
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1. Please state in your response letter whether FIN wil or has reviewed the
proposed underting terms and arangements of the transaction involved in the
registration statement.
2. Explain to the staff whether the Funds wil fie post-effective amendments in
order to sell securities off the shelf or whether they propose to file supplements under
Rule 497. Ifthe latter, advise the staff how the legal opinon and financial statements
wil be updated.
3. The pricing table on the facing page discloses the amount of securities being
registered. Confirm that securties to be used to fulfill any over-allotments wil be
included in the amount being registered.
4. Please see the U.S. Securties and Exchange CoInssion, A Plain English
Handbook (1998). Please review and revise the disclosure where it appears necessar so
as to assure conformty with the Commssion's plain English requirements. For example,
reformat disclosures appearg in all capita letters on the cover of the Statement of
Additional Information and elsewhere in the document. Please use a different means to
make the disclosure prominent (e.g., bold). Clarfy the types of indices refered to in the
following underlined clause: "The Fund may also purchase and sell options on securties
indices and other fiancial indices." (Emphasis added.) Clarfy the meanng of the
following disclosure: "Their discretionar target bonus is set at a percentage of the
respective base salar, rangig from 300% to 600%, with a maximum anual bonus
opportty of 150% of the target bonus." Last of all, confirm that the disclosure in the
fiing meets the type size requirements of Rule 420 of Regulation C under the Securties
Act.
5. We note that the Funds did not include covers letter with their registration
statements indicating the purose of the filings. In the futue, we suggest each Fund
include wrtten correspondence with every filing indicating the name and the telephone
number of the person to be contacted for information regarding the submission, the
purose of the filing, and whether it contains any novel or special issues, or disclosure,
that warant staff attention. .
6. The facing page indicates that each filing was made under Rule 415. Explain to
the staff the enumerated paragraph of the rue upon which the Funds are relying to make
the offerings.
Prospectus
7. Add the underlined clause to the following disclosure captioned "Cautionar
Notice Regardig Forward-Lookig Statements": "The forward-looking statements
contained in ths prospectus and any accompanyig prospectus supplement and the
statement of additional information are excluded from the safe harbor protection provided
by section 27A of the Securties Act of 1933, as amended (the '1933 Act)."
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8. The fist paragraph of disclosure captioned "Prospectus Sumar - Distrbutions"
discusses djstrbution history. Each Fund discloses in the first sentence that it has made
regular distrbutions to its shareholder~ for a specified perod. Specify the natue of the
distrbution (e.g., net investment income). The second sentence of ths discussion in the
Global Total Retu prospectus discloses that: "Additionally, the Fund has made periodic
distrbutions oflong-ter capital gains since inception." (Emphasis added.). Confirm that
such distrbutions complied with § 19(b) under the 1940 Act and Rule 19b-l thereunder.
9. The second and thrd paragraphs under ths caption discuss Global Total Retu's
curent managed distrbution policy and its efforts to obtain an SEC order to implement
such a plan. The disclosure regarding its curent policy indicates, among other thgs,
that distributions may include net investment income, net realized short-term capital gain
and, if necessar, retu of capital; and that at ties it may payout more or less than the
entire amount of income eared. Briefly state how the Fund expects the policy might
change if the order is granted. Provide disclosure that distinguishes managed
distrbutions from tre yield and disclose any adverse ta implications of the Funds'
curent policies. .
The same disclosure discusses the possibilty that the Fund's distrbutions may
constitute retus of capital and that: "To the extent the Fund distrbutes an amount in
excess of the Fund's curent and accumulated eargs and profits, such excess, if any,
will be treated by a shareholder for federal income tax puroses as a tax-free retu of
capital to the extent of the shareholder's adjusted tax basis in his, her or its shares and
thereafter as a gain from the sale or exchange of such shares." With respect to such
distrbutions, provide additional disclosure in the prospectus regarding i) the effect of a
distrbution on a shareholder's basis, and ii) if applicable, that a substantial amount of the
distrbutions in any year will be a retu of capitaL.
i O. Disclosure in the four paragraph states: "Since not all investors can parcipate
in the automatic dividend reinvestment plan, you should contact your broker or nominee
to confirm that you are eligible to parcipate in the plan." (Emphasis added.) Explai
why some investors may not paricipate in the plan.
11. The next sub-caption, "Investment Policies," contains disclosure which states
that: "Under normal circumstances, the Fund will invest at least30% ofits managed
. assets in securties of foreign issuers." A foreign issuer is defied as a foreign
governent or a company organed under the laws of a foreign countr. Some
companes are incorporated in a foreign countr, yet derive substantial revenue from, and
have substantial assets in, the U.S. Wil the Fund treat that company as a foreign issuer?
If yes, disclose that fact and how it affects the global natue of an investment in the Fund.
12. The last paragraph under ths sub-caption discloses that: "The Fund may invest in
other securties of varous tyes to the extent consistent with its investment objective."
Ths policy suggests the Fund may acquire whateverit wants whether or not disclosed in
the prospectus. Either delete ths disclosure or explain its meang to the staff
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13. Revise the introductory paragraph preceding the fee table so as to update the
information presented therein as of October 2006.
14. Revise the fee table consistent with the following:
. in light of each Fund's planed investments in other investment
companes, add an additional line item for Acquired Fund Fees and
Expenses (See Investment Company Act Release No. 27399 (June 20,
2006)),
. with respect to the management fee line item, add a footnote that explains
how the Fund conver the advisory fee from managed to net assets,
. revise Footnote 3 by adding disclosure regarding the amount of leverage
assumed to have been intiated durg the period covered by the table.
Furer, any debt contemplated for the next succeeding year should be
included in ths calculation,
. with respect to the discussion in Footnote 5 for Converble Opportties
and Converible High Income regarding the adviser's agreement to waive
fees, disclose that the adviser or an affliate may not recaptue any waived
amounts and whether the waiver may be termated at any time. Furter,
each footnote may on:y show the reduction applicable to the 2009 period
and disclosure should be added to the footnote that explains how the
calculation was converted to a net number,
· explain to the staff how such waivers and reimbursements are reflected in
the example calculations for the 1,3,5, and 10 year periods, and
· delete Footnote 4, because it may confuse investors.
15. The second and thd paragraphs of the discussion captioned "Investment
Objective and Pricipal Investment Strategies - Pricipal Investment Strategies" disclose
that the Fund wil dynamically allocate its investments though all market cycles using
multiple strategies, either separately or in combination. Reconcile ths policy, which
suggests faily active tuover of securties, with the following disclosure sub-captioned
"Portfolio Tumovet': "Although the Fund does not purchase securties with a view to
rapid turnover. . ."
16. If in connection with its global operations the Fund wil engage il European as
well as American style options, revise the option disclosure to discuss that policy.
17. The prospectu for each Fund, except Converible Opportties, coritais the
following disclosure: "Other Income Securities. The Fund may also invest in investment
grade income securties. The Fund's investments in investment grade income securties
may have fixed or varable principal payments and all types of interest rate and dividend
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payment and reset terms, including. . ." The disclosure is vague~ Clarfy the tye of
securties involved and disclose the associated risks.
18. Similarly, disclosure under the sub-caption "Pricipal Investment Strategies" in
the Converible Opportties prospectus states that: "Investments in Equity Securities.
Consistent with its objective, the Fund may invest in equity securties. Equity securities,
such as common stock, generally represent an ownership interest in a company."
Disclose the types of equity securities in which a Fund may invest.
19. If appropriate, revise the disclosure captioned "REIT Risk" for both Convertible
High Income and Convertible Opportties to reflect any new risks associated with sub-
prie loans and the current mortgage markets.
20. Revise the disclosure captioned "Risk Factors - Additional Risks to Common
Shareholders" to indicate that all leverage and related expenses are expenses paid solely
by common shareholders.
21. Revise the following disclosure to state specifically that the advisory fee creates a
conflict of interest for Calamos: "Because Calamos' investment management fee is a
percentage of the Fund's managed assets, Calamos' fee wil be higher if the Fund is
leveraged and Calamos wil have an incentive to be more aggressive and leverage the
Fund."
22. Disclosure sub-captioned "Market Discount Risk" states the following:
"Depending on the premium of the Fund's common shares, the Fund's net asset value
may be reduced immediately followig ths offering by the offering costs for common
shares, including the sales load, which wil be borne entirely by all common
shareholders." Explai the extent to which sales loads are expected to be born by
common shareholders.
23. Revise the disclosure captioned "Description of Securities - Common Shares" by
adding the indicated underlined clause: "Common shares, when issued and. outstanding,
wil he legally issued. fuly paid and non-assessable." Furter, clarfy the following in
the next sub-caption: "Under the 1940 Act, the Fund may on:y issue one class of
preferred shares. So long as any prefered shares are outstanding, additional issuances of
preferred shares must be of the same class as preferred shares and may not have
preference or priority over the preferred shares upon the distrbution of assets of the
Fund." (Emphasis added.)
24. In connection with a discussion of the Food's policy that shareholders seeking to
nominate trstees or transact other business at an anual meeting, disclosure captioned
"Certain Provisions of The Agreement and Declaration of Trust and Bylaws," provides
that: "Any notice by a shaehotder must be acmpaned by ce inormation as provided in
the Bylaws." Briefly descrbe the natue of the inormation to he provided by shareholder.
Statement of Additional Information
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25. Disclosure sub-caption "Debt Securties" states that: "There are no restrctions as
to the ratings of debt securties acquired by the Fund or the porton of the Fund's assets
that may be invested in debt securties in a paricular ratings category." Add ths
disclosure to the prospectu sumar.
26. Disclose the amount of assets which may be invested in Synthetic Foreign Money
Market Positions and Strctued Products. With respect to the latter, ífthe Fund's
strctued investments may include mortgagé related investments or other investments
materially effected by sub-prime mortgages, add appropriate risk disclosure.
27. Disclosure under the sub-caption "Other Investment Companes" indicates that
each Fund may invest in other investment companes subject to the limits in § 12(d) of the
1940 Act and goes on to state that: "These litations do not apply to the purchase of shares
of mon~y market fuds . .." Conf to the sta that eah Fund's tranactions regardig
money market fuds has and will satisfy the conditions and requiements of Rule 12dl-l
under the 1940 Act.
28. . Disclosure regarding portfolio manager compensation captioned ~'Management of
the Fund - Portfolio Managers" indicates that managers receive a discretionar target
bonus. If the compensation is based on performance determined or measured'relative to a .
benchmark, identify the benchmark and disclose the measurng period to be used to
determine compensation.
** * * * * ** * **
We note that portions of the filings are incomplete. We may have additional
comments on such portons when you complete them in a pre-effective amendment, on
disclosures made in response to ths letter, on information supplied in your response
letter, or on exhbits added in any pre-effective amendments.
Whenever a comment is made in one location, it is considered applicable to all
similar disclosure appearing elsewhere in the registration statements.
Response to this letter should be in the form. of pre-effective amendments filed
pursuant to Ru1e 472 under the Securities Act. Where no change wil be made in the
fiings in response to a comment, please indicate this fact in your response letter and
briefly state the basis for your position. Where changes are made in response to our
comments provide information regarding the natue ofthe change and, if appropriate, the
location of-such new or revised disclosure in the amended filings. As required by the
rule, please insure that you mark new or revised disclosure to indicate change.
rlease advise us if you have submitted or expect to submit an exemptive
application or no-action request in connection with your registration statements.
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