SecProbe.io

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 FOXBY CORP.
 2255 Buffalo Road
 Rochester, NY 14624

 June 5, 2025

 VIA EDGAR CORRESPONDENCE

 Ken Ellington
 Staff Accountant
 U.S. Securities and Exchange Commission
 Division of Investment Management, Disclosure Review and Accounting Office

 Re:

 Response to Comments on Form N-CSR and Form N-CEN for the twelve months ended December 31, 2024 of Foxby Corp. (the “Registrant” or “Fund”) (811-09261)

 Dear Mr. Ellington:

 On behalf of the Registrant, set forth below are the comments that you (the “Staff”) provided by telephone on June
 2, 2025 concerning the Fund’s Form N-CSR, filed with the Securities and Exchange Commission (the “SEC”) on February 27, 2025, and the Registrant’s response thereto.

 1.

 Comment: Please confirm if there has been
 a material change to the Fund’s principal investment strategy or principal risks or a change in the persons who are primarily responsible for the day-to-day management of the Fund.  If so, please confirm the Fund has disclosed these changes
 in the shareholder reports.  See Rule 8b-16 of the Investment Company Act of 1940.

 Response: The Registrant
 confirms there have been no changes within the reporting period to the items set forth above.

 2.

 Comment : Please explain why the most
 recent annual report did not include the following legend in the policies and updates section: “the following information [in this annual report] is a summary of certain changes since [date].  This information may not reflect all the
 changes that have occurred since you purchased [this fund].”  See Rule 8b-16(e).

 Response: The
 Fund will include the above legend on a going-forward basis commencing with its next report on Form N-CSR.

 3.

 Comment: In future filings, please
 include the Fund’s current investment objectives, investment policies, principal risks, and any material changes thereto in a single location of the financial report separate from the notes to the financial statements.  See AICPA expert
 panel meeting minutes dated May 17-18, 2021.

 1

 Response:
 The Fund will make the requested changes commencing with its next report on Form N-CSR.

 4.

 Comment: Please include disclosure
 responsive to items 4(i) and 4(j) of Form N-CSR in all future Form N-CSR filings even if those items are not applicable to the Registrant.

 Response: The
 Fund will make the requested changes commencing with its next report on Form N-CSR.

 *   *   *   *   *

 Should you have any further comments on these matters, or any questions, please contact me at (212) 785-0900, extension 275, or
 rkamerman@performancedriven.us.

 Sincerely,

 FOXBY CORP.

   By:
 /s/ Russell Kamerman

  Name: Russell Kamerman

  Title: General Counsel

  CC:

   Pamela M. Krill, Esq.

   Godfrey & Kahn, S.C.

 2

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FOXBY CORP.

11 Hanover Square

12th Floor

New York, NY 10005

March 22, 2017

VIA EDGAR CORRESPONDENCE

Lauren Hamilton

Division of Investment Management

Securities and Exchange Commission

100 F Street, N.E.

Washington, D.C. 20549

Re:

Responses to Comments on Form N-CSR for the twelve months ended December 31, 2015 of Foxby Corp. (the "Fund") (811-09261)

Dear Ms. Hamilton:

On behalf of the above-referenced registrant, set forth below are the comments that you (the "Staff") provided by telephone on March 3, 2017 concerning the Fund's annual report on Form N-CSR for the twelve months ended December 31, 2015 (the "Report") which was filed with the Securities and Exchange Commission (the "SEC") on March 9, 2016, and the Fund's responses thereto.  The Fund hereby confirms that the Staff has not requested that the Report be amended and re-filed with the SEC.

1.

Comment: In future filings, to the extent applicable, please include the share class for the Fund's investments in other mutual funds listed in the Schedule of Portfolio Investments.

Response: To the extent applicable, the Fund will make the requested changes commencing with its next report on Form N-CSR.

2.

Comment: With respect to the distributions noted in the Financial Highlights and the Statement of Changes in Net Assets in the Report, please confirm that the Fund complied with Section 19(a)(1) of the Investment Company Act of 1940, as amended (the "1940 Act").  Further, please confirm that the Fund does not use the terms "dividend" or "yield" on its website to identify the portion of a distribution which may be a return of capital.

Response: To the extent applicable, the Fund hereby confirms that it complied with Section 19(a)(1) with respect to the distributions noted in the Financial Highlights and the Statement of Changes in Net Assets in the Report.  Additionally, the Fund confirms that it does not use the terms "dividend" or "yield" on its website to identify the portion of a distribution which may be a return of capital.

* * * * *

Should you have any further comments on these matters, or any questions, please contact me at (212) 785-0900, extension 208, or jramirez@foxbycorp.com.

Sincerely,

/s/ John F. Ramírez

General Counsel

cc: Pamela M. Krill, Esq.

    Godfrey & Kahn, S.C.

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FOXBY CORP.

11 Hanover Square

New York, NY 10005

June 13, 2014

VIA EDGAR

Mr. Chad Eskildsen

Staff Accountant

U.S. Securities and Exchange Commission

Division of Investment Management, Disclosure Review and Accounting

100 F Street N.E.

Washington D.C. 20549

    Re:   Responses to Comments on Form N-PX filed by Foxby Corp. (the “Registrant”) on August 29, 2013

Dear Mr. Eskildsen:

On behalf of the Registrant, set forth below is the comment that you (the “Staff”) provided to me and Mr. Eric Paul C. Hwang, Chief Compliance Officer of the Registrant, by telephone on June 10, 2014 concerning the Form N-PX (Annual Report of Proxy Voting Record of Registered Management Investment Company) filed by the Registrant with the U.S. Securities and Exchange Commission (“SEC”) on August 29, 2013, and the Registrant’s responses thereto.  Your comments are set forth in italics and are followed by the Registrant’s responses.  Unless otherwise noted, terms used but not defined have the same meanings as in the Form N-PX.

Comment:  Pursuant to Form N-PX General Instruction F.2(a), Form N-PX “must be signed by the registrant, and on behalf of the registrant by its principal executive officer or officers.”  During a recent review, the Staff noted that the Form N-PX filed by the Registrant on August 29, 2013 was not signed by the Registrant’s principal executive officer. The Staff requests that the Registrant amend and file the Form NP-X with the principal executive officer signing on behalf of the Registrant.

Response:  The Registrant made the requested changes and filed an amended Form N-PX on June 13, 2014.

*           *           *           *           *

The Registrant acknowledges that:  (1) it is responsible for the adequacy and accuracy of the disclosures it makes in the Form NP-X; (2) Staff comments or changes to disclosure in response to Staff comments with regards to the Form NP-X reviewed by the Staff do not foreclose the SEC from taking any action with respect to the Form NP-X filed by the Registrant; and (3) it may not assert Staff comments as a defense in any proceeding initiated by the SEC or any person under the federal securities laws of the United States.

Please contact me at 212-785-0900, extension 208, if you have any questions regarding the foregoing.  Thank you for your time and attention to this matter.

Sincerely,

/s/ John F. Ramirez, Esq.

cc:  Thomas B. Winmill, Esq.

       R. Darell Mounts, Esq., K & L Gates LLP

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FOXBY CORP.

11 Hanover Square

New York, NY 10005

www.FoxbyCorp.com

VIA EDGAR

August 23, 2012

Mr. Larry L. Greene

Office of Disclosure and Review

Securities and Exchange Commission

100 F Street, NE

Washington, DC  20549

Re:

Responses to Comments on the Preliminary Proxy Statement of Foxby Corp. (SEC File No. 811-09261)

Dear Mr. Greene:

On behalf of Foxby Corp. (“Fund”), set forth below are the comments that you provided to Fatima Sulaiman of K&L Gates LLP, by telephone on July 26, 2012 and August 20, 2012, concerning the Fund’s preliminary proxy statement which was filed with the U.S. Securities and Exchange Commission (“SEC”) on July 20, 2012, and the Fund’s responses thereto.  Your comments are set forth in italics and are followed by the Fund’s responses.  Defined terms used but not defined herein have the respective meanings ascribed to them in the preliminary proxy statement.

1.

Comment:  Confirm that the disclosure in the definitive proxy statement when it is mailed to shareholders will meet the type size requirements of Rule 420 under Regulation C of the Securities Act of 1933.

Response:  We confirm that the disclosure in the proxy statement when it is mailed to shareholders will meet the type size requirements of Rule 420 under Regulation C of the Securities Act of 1933.

2.

Comment:  Confirm the legal basis for CEF Advisers providing advisory services to the Fund under the Interim Management Agreement.

Response:  CEF Advisers is providing advisory services to the Fund under the Interim Management Agreement pursuant to Rule 15a-4(b)(1) under the Investment Company Act of 1940, as amended.

3.

Comment:  Provide additional information about the Midas Family Trust.  We refer you to the American Century no-action letter (February 2, 2012).  Consider the parameters of disclosure provided by American Century in discussing their trust arrangement.

Response:  The Fund has revised the disclosure in the “Background” section of the proxy statement discussing Proposal 1 to provide additional information about the Midas Family Trust.

4.

Comment:  The Fund notes in the letter to shareholders, the “Questions and Answers Regarding the Proposals” section, and the proxy statement that the change from CEF Advisers to Midas Management is for “corporate administrative reasons.”  Supplementally explain what is meant by “corporate administrative reasons.”

Response:  The change from CEF Advisers to Midas Management is for “corporate administrative reasons” by virtue of the fact that Midas Management currently serves as the investment manager of three other funds in the Fund Complex:  Midas Fund, Inc., Midas Magic, Inc. and Midas Perpetual Portfolio, Inc.  Currently, CEF Advisers only serves as the investment manager to the Fund.  Since the principal executive officers and the members of the Investment Policy Committees of Midas Management and CEF Advisers are identical, the Fund believes that it is more practical and would result in greater administrative efficiency if Midas Management served as the Fund’s investment manager as well.

5.

Comment:  The Fund notes in the letter to shareholders, the “Questions and Answers Regarding the Proposals” section, and the proxy statement that its Board determined that the increased management fee “is fair and reasonable given that the current management fee is materially below the average advisory/management fee of the Fund’s peer group of funds.”  Please supplementally confirm to the Staff what the Fund’s peer group is.  Please state what is the average advisory/management fee of the Fund’s peer group.

Response:  The Fund’s peer group is comprised of a group of broadly comparable funds selected by Lipper, Inc., an independent data service.  We have revised the section in the Proxy Statement entitled “Evaluation by the Fund’s Board” to included additional information regarding the average advisory/management fee of the Fund’s peer group, as reported by Lipper.

6.

Comment:  In the letter to shareholders, convert the proposed advisory fee rate of 0.95% of the Fund’s weekly average managed assets to a net assets figure so that shareholders are presented an “apples-to-apples” comparison.

Response:  In response to your comment, the Fund has revised the disclosure in the shareholder letter regarding the proposed advisory fee rate as follows:

The new investment management agreement reflects two material changes: (i) a fee rate increase and (ii) a modification of the fee calculation methodology so that the management fee is calculated based on “managed assets” (which includes all Fund assets attributable to borrowing) rather than net assets.  Under the new agreement, the management fee rate would increase to a monthly fee at the annual rate of 0.95% of the Fund’s “managed assets.”  Under the prior investment management agreement the Fund paid a monthly fee at an annual rate of 0.50% of the Fund’s average daily net assets.  Calculated as a percentage of average daily net assets, the fee rate under the new investment management agreement would also be 0.95%.  However, because “managed assets” includes amounts borrowed, while “net assets” does not, a management fee based on managed assets rather than net assets would result in a higher fee to Midas Management if the Fund were to employ leverage because, in addition to the annual rate being higher, that higher rate would be applied to a broader asset base.  The Fund’s Board of Directors believes that the fee increase is fair and reasonable given that the current management fee is materially below the average advisory/management fee of the Fund’s peer group of funds.

-2-

7.

Comment:  Include disclosure in the “Questions and Answers Regarding the Proposals” section and the proxy statement about the potential conflict of interest that may arise from the investment manager being compensated based on “managed assets” rather than net assets.  Please also confirm whether the Fund anticipates changing its leverage policy or increasing its use of leverage.

Response:  In response to your comment, the Fund has added the following disclosure to the “Questions and Answers Regarding the Proposals” section and to the proxy statement:

“If the New Management Agreement is approved by shareholders, and the Fund employs leverage, Midas Management could be viewed as having an economic incentive to utilize leverage because the use of leverage would increase the Fund’s managed assets and hence the fee paid by the Fund to Midas Management.”

As the Fund discloses in the “Questions and Answers Regarding the Proposals” section and in the proxy statement, it does not employ leverage; however, the Fund reserves the right to adjust leverage from time to time up to the maximum permitted under the 1940 Act.

8.

Comment:  In the “Questions and Answers Regarding the Proposals” section and the proxy statement, the Fund defines “managed assets” as the “average weekly value of the Fund’s total assets minus the sum of the Fund’s liabilities, which liabilities exclude debt relating to leverage, short-term debt and the aggregate liquidation preference of any outstanding preferred stock.”  Please add disclosure that describes the forms of leverage that the Fund may use.

-3-

Response:  The Fund has added disclosure to the “Questions and Answers Regarding the Proposals” section and to the proxy statement that states that the Fund may obtain leverage through borrowings, the issuance of short term debt securities, the issuance of shares of preferred stock, derivative transactions, loans of portfolio securities, and when-issued, delayed delivery and forward commitment transactions.

9.

Comment:  On page 2 of the proxy statement, please make more clear that the 24.47% beneficial ownership of Fund shares reported by Midas Securities Group, Inc., Winmill & Co. Incorporated, Winmill Family Trust, Thomas B. Winmill, and Mark C. Winmill represents record or beneficial ownership in the same Fund shares.

Response:  The Fund has added disclosure to the proxy statement that clarifies that the 24.47% beneficial ownership of Fund shares reported by the above entities represents record or beneficial ownership in the same Fund shares.

10.

Comment:  Please add disclosure to the discussion of quorum and adjournment on page 2 of the proxy statement that clarifies the effect of abstentions and broker non-votes on a vote to adjourn the Meeting.

Response:  Pursuant to the Fund’s bylaws, the chairman of the Meeting has the power to adjourn the Meeting from time to time to a date not more than 120 days after the Record Date.  As such, abstentions and broker non-votes will not have an impact on the chairman’s determination to adjourn the Meeting.  The Fund has added disclosure to this effect to the proxy statement.

11.

Comment:  On page 4 of the proxy statement, the Fund states that Winmill & Co. Incorporated is the parent company of CEF Advisers, but later refers to “the control entities of CEF Advisers.”  Please revise this disclosure, as necessary, to describe the other control entities of CEF Advisers.

Response:  The Fund has added disclosure to the proxy statement stating that in addition to Winco, the Trust, Thomas Winmill, and Mark Winmill may also be deemed to be control entities of CEF Advisers.

-4-

12.

Comment:  On page 5 of the proxy statement, the Fund states that the New Management Agreement “clarifies that the Fund is responsible for the cost of certain reports and statistical data requested or approved by the Fund’s Board and modifies the procedures for the payment of certain Fund expenses.”  Confirm that these costs are captured in the comparative fee and expense table on page 7 of the proxy statement.

Response:  The Fund confirms that the above expenses are captured in the comparative fee and expense table in the proxy statement.

13.

Comment:  In the comparative fee and expense table on page 7 of the proxy statement, actual fees are calculated on the basis of the Fund’s average net assets while pro forma fees are calculated on the basis of “managed assets.”  Confirm in your response letter that the Staff does not permit the side-by-side comparison of expenses calculated based on net assets and “managed assets.”  Add disclosure to the proxy statement that clarifies for shareholders that if the Fund uses leverage, the asset base on which the management fee would be calculated would be higher than the asset base under the current management fee structure.

Response:  The Fund confirms that the Staff does not permit the side-by-side comparison of expenses calculated based on net assets and “managed assets.”  In response to your comment, the Fund has revised the Annual Expenses table in the proxy statement to include a side-by-side comparison of the Fund’s actual and pro forma annual expenses calculated on the basis of the Fund’s average daily net assets.  The Fund has also added the following in footnote 1 to the Annual Expenses table:

The actual and pro forma Annual Expenses assume that the Fund does not use any leverage.  If the Fund borrows an amount representing 331/3% (which is the maximum amount permitted by the 1940 Act) of the Fund’s total assets (including the proceeds of such borrowing, but not reflecting the amount of the liability of the borrowing), its management fee with the current fee in place would be 0.50% of its average daily net assets and its management fee with the proposed fee under the New Management Agreement in place would be 1.27% of its net assets.

The Fund has also added disclosure to the proxy statement that clarifies for shareholders that if the Fund uses leverage, the asset base on which the management fee would be calculated would be higher than the asset base under the current management fee structure.  Please see, e.g., the response to Comment 6 above.

-5-

14.

Comment:  Please change references to the Fund’s “independent auditors” to “independent registered auditors.”

Response:  The Fund has made the requested change throughout the proxy statement.

*           *           *           *           *

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

Please contact Fatima Sulaiman at (202) 778-9082 if you have any questions regarding the foregoing.  Thank you for your attention to this matter.

 Sincerely,

 /s/ John F. Ramirez

cc:           Thomas B. Winmill, Esq.

R. Darrell Mounts, Esq., K&L Gates LLP

Fatima Sulaiman, Esq., K&L Gates LLP

-6-

<DOCUMENT>
<TYPE>CORRESP
<SEQUENCE>1
<FILENAME>filename1.txt
<TEXT>
                                   Foxby Corp.
                            Global Income Fund, Inc.
                               11 Hanover Square
                               New York, NY 10005

August 24, 2007

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

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

Dear Mr. Greene:

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

                                      * * *

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

                                                    Very truly yours,

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

cc:      R. Darrell Mounts

</TEXT>
</DOCUMENT>

<DOCUMENT>
<TYPE>CORRESP
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<TEXT>
K&L/Gates                         Kirkpatrick & Lockhart Preston Gates Ellis LLP
                                  1601 K Street NW
                                  Washington, DC 20006-1600

                                  T 202.778.9000  www.klgates.com

August 2, 2007

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

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

Dear Mr. Greene:

         On behalf of Global Income Fund, Inc. and Foxby Corp. (each a
"Registrant" and together, the "Registrants"), set forth below is a comment that
you provided by telephone on July 26, 2007 to Yoon Choo of Kirkpatrick &
Lockhart Preston Gates Ellis LLP concerning the above-referenced preliminary
proxy statements (each a "Proxy Statement"). Your comment is set forth in
italics below and is followed by the Registrants' response. Responses to the
remainder of your comments will follow in a separate letter.

         COMMENT: PLEASE PROVIDE A COPY OF THE OPINION REFERENCED ON PAGE 1 OF
EACH PROXY STATEMENT. EXPLAIN WHETHER THAT OPINION CONSIDERS THE REQUIREMENTS OF
SECTION 18(I) OF THE INVESTMENT COMPANY ACT OF 1940, AS AMENDED (THE "1940
ACT"). IF THE OPINION DOES NOT ADDRESS SECTION 18(I), EXPLAIN HOW THE OPINION'S
STANCE ON THE APPLICABILITY OF THE MARYLAND CONTROL SHARE ACQUISITION ACT
("MCSAA") AND THE REQUIREMENTS OF SECTION 18(I) CAN BE RECONCILED. FINALLY,
PLEASE INDICATE WHETHER THIS OPINION WOULD BE CONTROLLING AUTHORITY FOR THE
REGISTRANTS.

         RESPONSE: As requested, a copy of NEUBERGER BERMAN REAL ESTATE INCOME
FUND INC. V. LOLA BROWN TRUST NO. 1B, ET AL. (the "Opinion") was forwarded to
you by e-mail on July 26, 2007. As you are aware, the MCSAA permits the boards
of Maryland corporations to opt into the protection of this statute, which
states, among other things, that "control shares" acquired in a "control share
acquisition" have no voting rights except to the extent approved by stockholders
of the corporation at a meeting held pursuant to certain provisions of the MCSAA
by the affirmative vote of  two-thirds of all the votes entitled to be cast on
the matter, excluding all "interested shares".(1)

<PAGE>

         The Opinion does not explicitly address the requirements of Section
18(i) of the 1940 Act.(2) We believe however that it was impossible for the
court to reach the conclusion it did in the Opinion without finding that use of
the MCSAA by a registered investment company does not violate Section 18(i) of
the 1940 Act. The court was made aware of the provisions of Section 18(i) of the
1940 Act by the parties to the litigation. Count two of the counterclaim
("Counterclaim") filed by the Horejsi Family Trusts (as defined in the
Counterclaim), seeks a declaratory judgment that Neuberger Berman Real Estate
Income Fund, Inc.'s (the "Fund") decision to "opt into" the MCSAA "violates
Section 18(i) of the 1940 Act" and is therefore "preempted by Section 18(i) of
the 1940 Act and under the Supremacy Clause of the United States
Constitution."  In the Counterclaim, the Horejsi Family Trusts request that
the court enter judgment that the MCSAA and the voting restrictions imposed by
Section 3-702(a)(1) of the MCSAA do not apply to any shares of the Fund owned by
the Horejsi Family Trusts.

         Instead of granting the relief requested by the Horejsi Family Trusts,
the court upheld the use of the MCSAA by the Fund and the voting restrictions
imposed by Section 3-702(a)(1) of the MCSAA. The court held that all control
shares acquired by the Horejsi Family Trusts before the Fund opted into the
MCSAA could be voted without restriction but that any exemption from the
restrictions of the MCSAA were capped at the number of control shares owned as
of the time the Fund opted into the MCSAA.(4) In upholding the Fund's use of the
MCSAA, albeit with limitations related to the timing of the opt-in, the court
explicitly affirmed the use of the MCSAA by the Fund. Although the Opinion is
silent regarding the requirements of Section 18(i), the court was clearly aware
of the issues raised by that section and had to consider those issues before
issuing the Opinion. Therefore, in upholding the Fund's use of the MCSAA, it is
impossible not to conclude that the court decided that the Fund's use of the
MCSAA does not violate Section 18(i) of the 1940 Act.

         The Opinion was issued by the United States District Court of the
District of Maryland, which was applying and interpreting Maryland law. Both
Registrants are Maryland corporations. Controlling authority with respect to
Maryland state law questions would be issued by the Court of Appeals of
Maryland, which has not addressed the subject question. However, in the absence
of controlling authority on point, the Registrants view the Opinion as the most
persuasive available authority regarding these matters.

                                      * * *

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

                                             Very truly yours,

                                             /s/ R. Darrell Mounts

cc:   Thomas B. Winmill

------------------------------------------

(1) "Control shares" are defined generally in Section 3-701(d) of the MCSAA as
shares of stock that entitle a person, directly or indirectly, to exercise or
direct the exercise of the voting power of shares of stock of the corporation in
the election of directors within any of the following ranges of voting power:
(i) one-tenth or more, but less than one-third of all voting power; (ii)
one-third or more, but less than a majority of all voting power; or (iii) a
majority or more of all voting power.

"Control share acquisition" is defined in Section 3-701(e) of the MCSAA
generally as the acquisition, directly or indirectly, by any person, of
ownership of, or the power to direct the exercise of voting power with respect
to, control shares but does not include the acquisition of shares in a merger,
consolidation or share exchange to which the corporation is a party.

"Interested shares" is defined in Section 3-701(f) of the MCSAA as shares of a
corporation in respect of which an acquiring person, an officer of the
corporation, or an employee of the corporation who is also a director of the
corporation is entitled to exercise or direct the exercise of the voting power
of shares of stock of the corporation in the election of directors.

(2) Section 18(i) of the 1940 Act provides in relevant part that: "[e]xcept as
provided in subsection (a) of this section, or as otherwise required by law,
every share of stock hereafter issued by a registered investment company . . .
shall be a voting stock and have equal voting rights with every other
outstanding voting stock".

(3) The Fund's case was complicated because the MCSAA grandfathers a holder who
exceeds the 10% threshold before the corporation opts into the act's
protections. In this case, the Horejsi Family Trusts' beneficial ownership
increased from 4.9% to 10.2% almost overnight. Thus, before the Fund received a
Form 13D, the Horejsi Family Trusts' holdings exceeded the 10% threshold. In
order to finance a limited self-tender, the Fund made a $3 million private
placement of common stock with Neuberger Berman, LLC. This had the effect of
decreasing the Horejsi Family Trusts' holdings to just below 10% of the
outstanding shares, at which point the Board of the Fund opted into the MCSAA.
Because the Fund's self-tender subsequently shrank the pool of outstanding
shares, the Horejsi Family Trusts' holdings again exceeded 10%. At issue was
whether all or some of the shares owned by the Horejsi Family Trusts would be
subject to the MCSAA.

                                       2
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