DIVIDEND NOTICE
THE COMSTOCK FUNDS, INC.
COMSTOCK STRATEGY FUND

FOR IMMEDIATE RELEASE
Rye, New York
October 26, 2000


The Comstock Funds announced the monthly distribution from net investment income for the Comstock Strategy Fund. The dividend is payable on October 27, 2000 to shareholders of record on October 26, 2000. The ex-dividend, payment and reinvestment date is October 27, 2000.

Distribution (per share)
Class O $0.01171 per share
Class A $0.01081 per share
Class C $0.00839 per share

The Comstock Funds are managed by Gabelli Funds, LLC and distributed by Gabelli & Company, Inc., subsidiaries of Gabelli Asset Management Inc., which is a publicly traded NYSE listed company.

For further information call Bruce Alpert at 914-921-5105 or 1-800-GABELLI (1-800-422-3554).