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CORRESP
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            Stradley Ronon Stevens & Young, LLP

            2005 Market Street, Suite 2600

            Philadelphia, PA 19103-7018

            Telephone  215-564-8000

            Fax  215-564-8120

            www.stradley.com

    Mark A. Sheehan, Esq.

    (215) 564-8027

    msheehan@stradley.com

    May 19, 2020

    VIA EDGAR

    U.S. Securities and Exchange Commission

    Division of Investment Management

    100 F Street, N.E.

    Washington, D.C. 20549-9303

            Attention:

            Raymond Be, Esq.

            Senior Counsel

            Re:

            Global X Funds

            File No. 333-151713, 811-22209

    Dear Mr. Be:

    On behalf of Global X Funds (the “Registrant” or the “Trust”), and its series, the Global X Variable Rate Preferred ETF
      (the “Fund”), included in Post-Effective Amendment No. 593 (the “Amendment”) to the Registrant’s registration statement on Form N-1A (the “Registration Statement”), below you will find the Registrant’s responses to the comments that you had conveyed
      to the undersigned on April 27, 2020 with regard to the Amendment.  The Amendment was filed with the U.S. Securities and Exchange Commission (the “SEC”) on March 12, 2020, pursuant to the Investment Company Act of 1940, as amended (the “1940 Act”),
      and Rule 485(a)(2) under the Securities Act of 1933, as amended (the “Securities Act”).

    Below we have summarized your comments, in italics, and presented the Registrant’s response to each comment.  The
      responses will be incorporated into a post-effective amendment filing to the Registration Statement to be made pursuant to Rule 485(b) under the Securities Act.  Capitalized terms not otherwise defined in this letter have the meanings assigned to the
      terms in the Amendment.

      U.S. Securities and Exchange Commission

      Attention: Raymond Be, Esq.

      May 19, 2020

      Page 2

    PROSPECTUS

    PRINCIPAL INVESTMENT STRATEGIES

              1.

                Comment: Please provide more detail regarding the securities in which the Fund intends to invest (e.g., the entire market or
                    certain segments of the preferred securities market).

                Response: The Registrant has revised its principal investment strategies disclosure in order to clarify that the Underlying Index is designed to be representative of the entire market, as follows:

                The Underlying Index is designed to track the broad-based performance of the U.S.-listed variable rate preferred securities market.

              2.

                Comment: With regard to the sentence “Qualifying securities must meet minimum price, liquidity, maturity and other requirements
                    as determined by ICE Data Indices, LLC (the "Index Provider"),” please briefly state the types of securities that would meet these requirements.

                Response: The Registrant has revised its principal investment strategies disclosure as follows:

                  Qualifying securities must be issued in $25, $50, $100, or $1000 par/liquidation preference increments, must have a traded
                      market value of greater than $6 million in each of the previous three calendar months, and must have at least one year remaining to maturity, meet minimum price, liquidity, maturity and other requirements as determined by ICE Data Indices, LLC (the "Index Provider")

    SUMMARY OF PRINCIPAL RISKS

              3.

                Comment: The Staff notes that the principal risks appear in alphabetical order. Please order the risks to prioritize the risks
                    that are most likely to adversely affect the Fund’s net asset value, yield, and total return. Please note that after listing the most significant risks for the Fund, the remaining risks may be alphabetized. See ADI 2019-08, “Improving Principal Risks Disclosure” at www.sec.gov.

                Response: The Registrant acknowledges the Staff’s views on alternative approaches in disclosure presentation, however, after consideration of the issues, the Registrant believes its approach is
                  consistent with and sufficiently responsive to the requirements of Form N-1A at present. The Registrant respectfully declines to make the requested change at this time.

              4.

                Comment: Significant market events have occurred since the Amendment was filed, namely
                    as a result of the COVID-19 pandemic. Given that this is a fund that invests specifically in markets that may be destabilized as a consequence of the COVID-19 pandemic, please consider whether the Fund’s disclosures, including its risk
                    disclosure,

      U.S. Securities and Exchange Commission

      Attention: Raymond Be, Esq.

      May 19, 2020

      Page 3

              should be revised based on how these events are affecting both equity and debt markets. If the Registrant believes that no additional disclosure is warranted, please supplementally explain.

               Response: The
                  Registrant notes that the Amendment had contained updated “Geographic Risk” and “Recent Market Conditions” disclosure intended to reflect the effects of the COVID-19 pandemic on equity and debt markets. For your reference, that disclosure
                  is set forth below. In addition, the Registrant notes that it has updated its “Market Risk” disclosure to reflect the effect of the COVID-19 pandemic on debt markets as follows:

                SUMMARY OF PRINCIPAL RISKS

                Geographic Risk: A natural, biological or other disaster could occur in a geographic region in which the Fund invests, which could affect the economy or particular business operations of companies in the specific geographic region, causing an
                    adverse impact on the Fund’s investments in the affected region or in a region economically tied to the affected region. The securities in which the Fund invests and, consequently, the Fund are also subject to specific risks as a result
                    of their business operations, including, but not limited to:

                Market Risk: Turbulence in the financial markets and reduced liquidity may negatively
                    affect issuers, which could have an adverse effect on the Fund. If the securities held by the Fund experience poor liquidity, the Fund may be unable to transact at advantageous times or prices, which may decrease the Fund’s returns. In
                    addition, there is a risk that policy changes by the U.S. Government, central

                        governments and governmental agencies, including the Federal Reserve, or the other

                        government actorsEuropean Central Bank, which could include increasing interest rates, could cause increased volatility in
                    financial markets and lead to higher levels of Fund redemptions, which could have a negative impact on the Fund.Furthermore, local, regional or global
                        events such as war, acts of terrorism, the spread of infectious illness or other public health issue, recessions, or other events could have a significant impact on the Fund and its investments and trading of its Shares.
                    The Fund’s NAV could decline over short periods due to short-term market movements and over longer periods during market downturns.

                A FURTHER DISCUSSION OF PRINCIPAL RISKS

                Geographic Risk

                Geographic risk is the risk that the Fund’s assets may be concentrated in countries located in the same geographic region. This concentration will subject the Fund
                  to risks associated with that particular region, or a region economically tied to that particular region, such as a natural, biological or other disaster. Outbreaks of contagious viruses and diseases may reduce business activity or
                  disrupt market activity, and have the potential to

      U.S. Securities and Exchange Commission

      Attention: Raymond Be, Esq.

      May 19, 2020

      Page 4

              exacerbate market risks in the countries and regions in which they occur. The securities in which the Fund invests and, consequently, the Fund are also subject to
                specific risks as a result of their business operations, including, but not limited to:

              Market Risk

              Market risk is the risk that the value of the securities in which the Fund invests may go up or down in response to the prospects of individual issuers and/or general
                economic conditions. Turbulence in the financial markets and reduced market liquidity may negatively affect issuers, which could have an adverse effect on the Fund. If the securities held by the Fund experience poor liquidity, the Fund may
                be unable to transact at advantageous times or prices, which may decrease the Fund’s returns. In addition, there is a risk that policy changes by the U.S. Government, central governments and governmental agencies, including the Federal Reserve,
                or the other government actorsEuropean Central Bank, which
                could include increasing interest rates, could cause increased volatility in financial markets and lead to higher levels of Fund redemptions, which could have a negative impact on the Fund. Furthermore, local, regional or global events such as war, acts of terrorism, the spread of infectious illness or other public health issue, recessions, or other events could have a significant impact
                    on the Fund and its investments and trading of its Shares. The Fund’s NAV could decline over short periods due to short-term market movements and over longer periods during market downturns.

              STATEMENT OF ADDITIONAL INFORMATION – INVESTMENT OBJECTIVE, STRATEGIES AND RISK

              RECENT MARKET CONDITIONS. Although the Fund seeks to achieve
                its investment objective, the performance of the Fund is subject to general market conditions.

              Heading into Q4 2018, market participants largely expected a hawkish Federal Reserve to continue its rising rate cycle. However, prompted by
                sluggish growth and amidst contemporaneous urging by the U.S. government’s executive branch, the Federal Reserve cut rates three times in 2019. The consequences were felt throughout the course of the year and across financial markets. This
                loosening of monetary policy comes after four rate increases in 2018.  The Federal Reserve also restarted asset purchases in September of 2019. During Q1 2020, in response to the COVID-19 outbreak, the Federal Reserve shifted to a more
                dovish interest rate policy. Further interest rate cuts are likely to be considered during 2020. At this point, it is difficult to predict the impact of these stimulative actions and any future rate movements on various markets.

              Outside of the U.S., low growth and inflation prompted more easing from central banks in 2019. The European Central Bank began injecting €20
                billion a month into the economy after halting asset purchases at the end of 2018, while the Bank of Japan

      U.S. Securities and Exchange Commission

      Attention: Raymond Be, Esq.

      May 19, 2020

      Page 5

                signaled they were open to further interest rate cuts in the future, and China’s slowing economic growth prompted the People’s Bank of China’s first loan rate cut
                  in three years. These actions suppressed yields on fixed income assets globally and increased bond returns. It is possible that current monetary easing may reduce available tools for central banks to support future growth, particularly if
                  the global economy were to fall into a recession.

                Consumer spending in 2019 proved resilient, bolstered by strong employment figures, low interest rates, and falling oil prices, but business investment remained
                  muted by trade uncertainties, notwithstanding low interest rates and increasing margin pressures that would typically drive investment into areas that can reduce long-run costs and/or increase productivity.

                An outbreak of an infectious respiratory illness caused by a novel coronavirus known as COVID-19 was first detected in China in December 2019 and has subsequently
                  been detected globally. This coronavirus has resulted in travel restrictions, closed some international borders, enhanced health screenings at ports of entry and elsewhere, disruption of and delays in healthcare service preparation and
                  delivery, prolonged quarantines, cancellations, supply chain disruptions, and lower consumer demand, as well as general concern and uncertainty. It is possible that public health crises caused by the COVID-19 outbreak may exacerbate other
                  pre-existing political, social and economic risks in certain countries or globally. The duration of the COVID-19 outbreak and its effects cannot be determined with certainty as of the date of this SAI.

                It is impossible to predict the effects of these or similar events in the future on the Fund, though it is possible that these or similar events could have a
                  significant adverse impact on the NAV and/or risk profile of the Fund.

              5.

                Comment: With regard to the second sentence of “Preferred Stock Investment Risk” that states “As interest rates rise, the value
                    of the preferred stocks held by the Fund are likely to decline,” to what extent does this apply to the Fund since most of the Fund’s investments are in floating rate securities?

                Response:
                  The Registrant notes that it has updated its “Preferred Stock Investment Risk” disclosure as follows:

                SUMMARY OF PRINCIPAL RISKS

                Preferred Stock Investment Risk: Preferred stock is subject to many of the risks
                      associated with debt securities, including interest rate risk. As interest rates rise, the value of the preferred stocks held by the Fund are likely to decline. In addition, preferred stock may be subordinated to bonds or other debt instruments in an issuer’s capital structure, meaning that an issuer’s preferred stock generally pays dividends
                    only after the issuer makes required payments to holders of its bonds and other debt. Additionally, in certain situations, an issuer may call or redeem its preferred stock or convert it to common stock.

      U.S. Securities and Exchange Commission

      Attention: Raymond Be, Esq.

      May 19, 2020

      Page 6

              Preferred stock may be less liquid than many other types of securities, such as
                  common stock, and generally provides no voting rights with respect to the issuer.  Preferred stock is subject to many of the risks associated with debt securities, including risks associated with floating rate debt.

              A FURTHER DISCUSSION OF PRINCIPAL RISKS

              Preferred Stock Investment Risk

              Unlike interest payments on debt securities, dividend payments on a preferred stock typically must be declared by the issuer’s board of directors. An issuer’s board of
                directors is generally not under any obligation to pay a dividend (even if such dividends have accrued), and may suspend payment of dividends on preferred stock at any time. In the event an issuer of preferred stock experiences economic
                difficulties, the issuer’s preferred stock may lose substantial value due to the reduced likelihood that the issuer’s board of directors will declare a dividend and the fact that the preferr