DIVIDEND NOTICE
THE COMSTOCK FUNDS, INC. - COMSTOCK STRATEGY FUND

FOR IMMEDIATE RELEASE
Rye, New York
January 28, 2004


    The Comstock Funds announced the monthly distribution from net investment income for the Comstock Strategy Fund. The dividend is payable on January 28, 2004 to shareholders of record on January 27, 2004. The ex-dividend, payment and reinvestment date is January 28, 2004.

    Distribution (per share)
    Class O (Fund# 1791) $0.0065
    Class A (Fund# 1789) None
    Class C (Fund# 1790) None

    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 N. Alpert at 914-921-5105 or 1-800-GABELLI (1-800-422-3554).