Gyrodyne, LLC (GYRO)

[Enterprising Investor]

Bulldog Investors LLC beneficially owns 103,707 shares (9/01/15)

Controls 6.99 percent.

As per the supplement to the prospectus dated 7/1/15, there were 1,482,680 shares of common stock to be outstanding after the merger on 9/1/15. The percentages set forth herein were derived using such number. Phillip Goldstein, Andrew Dakos and Steven Samuels own Bulldog Investors, LLC, a registered Investment adviser. As of October 2, 2015, Bulldog Investors, LLC is deemed to be the beneficial owner of 103,707 shares of GYRO by virtue of Bulldog Investors, LLC's power to direct the vote of, and dispose of, these shares. These 103,707 shares of GYRO include 82,067 shares (representing 5.54% of GYRO's outstanding shares) that are beneficially owned by MR. Goldstein and the following entities over which Messrs. Goldstein, Dakos and Samuels exercise control: Opportunity Partners LP, Full Value Special Situations Fund LP, Full Value Partners LP, Bulldog Investors I (collectively, Bulldog Investors Group of Funds). Bulldog Investors Group of Funds may be deemed to constitute a group. All other shares included in the aforementioned 103,707 shares of GYRO owned by Bulldog Investors, LLC (solely by virtue of its power to sell or direct the vote of these shares) are also beneficially owned by clients of Bulldog Investors, LLC who are not members of any group. The total number of these "non-group" shares is 21,640 shares (representing 1.45%) of GYRO's outstanding shares).

http://www.sec.gov/Archives/edgar/data/1504304/000150430415000118/thirteeng.txt