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

FOR IMMEDIATE RELEASE
Rye, New York
May 28, 2003


    The Comstock Funds announced the monthly distribution from net investment income for the Comstock Strategy Fund. The dividend is payable on May 28, 2003 to shareholders of record on May 27, 2003. The ex-dividend, payment and reinvestment date is May 28, 2003.

    Distribution (per share)
    Class O (Fund# 1791) $0.00503
    Class A (Fund# 1789) $0.00422
    Class C (Fund# 1790) $0.00166

    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).