DIVIDEND NOTICE
THE COMSTOCK FUNDS, INC.
COMSTOCK STRATEGY FUND

FOR IMMEDIATE RELEASE
Rye, New York
May 29, 2002

    The Comstock Funds announced the monthly distribution from net investment income for the Comstock Strategy Fund. The dividend is payable on May 29, 2002 to shareholders of record on May 28, 2002. The ex-dividend, payment and reinvestment date is May 29, 2002.

    Distribution (per share)
    Class O $0.00753
    Class A $0.00675
    Class C $0.00412

    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).