On December 2, 2019, Special Opportunities Fund, Inc. (the “Fund”) submitted a request for a determination to the Staff of the Division of Investment Management of the Securities Exchange Commission (the “Staff”) as to whether certain potential amendments to the Fund’s by-laws would contravene the Investment Company Act of 1940, particularly Sections 16(a), 18(i) and 36(a). The proposed amendments include share ownership limitations, a majority voting requirement for director election, and a continuing director by-law which would confer certain powers specifically upon continuing directors. The Fund’s Board has not taken any action relating to the adoption of proposed amendments to the Fund’s by-laws and will consider the Staff’s determination before taking any such actions.

(d) Exhibits

SPECIAL OPPORTUNITIES FUND, INC. Exhibit
EX-99.1 CHARTER 2 fundltr.htm FUND LETTER   Special Opportunities Fund,…
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About SPECIAL OPPORTUNITIES FUND, INC. (NYSE:SPE)

Special Opportunities Fund, Inc. (the Fund) is a diversified closed-end management investment company. The Fund’s investment objective is to achieve total return. The Fund’s investment portfolio consists of investment companies, common stocks, commodity partnerships, preferred stocks, money market funds, corporate notes, liquidation claims, corporate bonds, promissory notes, warrants and rights. The Company also invests in various sectors, such as food products, insurance, information technology services, professional services, real estate investment, trusts software and special purpose acquisition vehicle. The Fund also invests in closed-end funds, auction rate preferred securities, business development companies and real estate investment trusts, among others. Bulldog Investors LLC acts as an investment advisor for the Fund.