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 Document Global X Funds 605 Third Avenue, 43 rd Floor New York, NY 10158 July 8, 2025 VIA EDGAR U.S. Securities and Exchange Commission Division of Investment Management 100 F Street, N.E. Washington, D.C. 20549-9303 Attn: Ms. Karen Rossotto, Esq. Re:      Global X Funds File No. 333-151713, 811-22209 Dear Ms. Rossotto: On behalf of Global X Funds (the “Registrant” or the “Trust”) and its series, the Global X PureCap SM MSCI Consumer Discretionary ETF, the Global X PureCap SM MSCI Communication Services ETF, the Global X PureCap SM MSCI Information Technology ETF, the Global X PureCap SM MSCI Consumer Staples ETF and the Global X PureCap SM MSCI Energy ETF (each a “Fund” and together, the “Funds”) included in Post-Effective Amendment No. 820, (the “Amendment”) to the Registrant’s registration statement on Form N-1A (the “Registration Statement”), below you will find the Registrant’s responses to oral comments provided on June 18, 2025 with regard to the Amendment. The Amendment was filed with the U.S. Securities and Exchange Commission (the “SEC”) on April 25, 2025 and re-filed on May 1, 2025, 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”). Global X Funds 605 Third Avenue, 43 rd Floor New York, NY 10158 Below we have summarized your comments, in italics , and presented the Registrant’s response to each comment. Capitalized terms not otherwise defined in this letter have the meanings assigned to the terms in the Registration Statement. GLOBAL X PURECAP MSCI CONSUMER DISCRETIONARY ETF - PROSPECTUS - PRINCIPAL INVESTMENT STRATEGIES 1.      Comment : In the first paragraph of the indicated section, please delete the word “substantially” from the phrase “economic characteristics that are substantially similar to the economic characteristics of the Underlying Index's component securities.” Response : The Registrant has deleted the indicated text. 2.      Comment : In the first sentence of the second paragraph of the indicated section, please delete “as presently constituted”. Response : The Registrant has updated this text as shown in Comment 4 below. 3.      Comment : With regard to the initial universe of the Underlying Index, please disclose the number of components and the market capitalization of the components. Response : The Registrant has added the following statement and similar statements to each Fund’s prospectus: The Underlying Index is designed to track the performance of U.S. securities included in the MSCI USA Index that fall within the Consumer Discretionary sector based on the MSCI and S&P Dow Jones Indices' Global Industry Classification Standard (GICS ® ), as determined by MSCI Inc. (“MSCI” or the "Index Provider"). As of July 1, 2025, the Underlying Index had 50 constituents with a market capitalization between $9.8 billion and $2.3 trillion. The Registrant has also provided the number of components and the market capitalization ranges for each index below:   • MSCI USA Consumer Discretionary Index:  o Number of holdings: 50 Global X Funds 605 Third Avenue, 43 rd Floor New York, NY 10158 o Market Cap Range: $9.8 billion - $2.3 trillion   • MSCI USA Communication Services Index:  o Number of holdings: 24 o Market Cap Range: $14.4 billion - $2.1 trillion   • MSCI USA Information Technology Index: o Number of holdings: 86 o Market Cap Range: $11.6 billion - $3.7 trillion   • MSCI USA Consumer Staples Index:  o Number of holdings: 37 o Market Cap Range: $9.4 billion - $784.0 billion   • MSCI USA Energy Index: o Number of holdings: 23 o Market Cap Range: $18.2 billion - $470.8 billion 4.      Comment : With regard to the first three paragraphs, please revise to better follow plain English principles. Response : The Registrant has updated the indicated paragraphs as follows: Under normal circumstances, the Fund invests at least 80% of its net assets, plus the amount of any borrowings for investment purposes (if any), in the Consumer Discretionary sector . This is accomplished by investing in the component securities of the Underlying Index or in investments (either directly or indirectly through exchange traded funds (“ETFs”)) that have, either individually or in the aggregate, economic characteristics that are substantially similar to the economic characteristics of the Underlying Index’s component securities. The Fund's 80% investment policy is non-fundamental and requires 60 days prior written notice to shareholders before it can be changed. The Underlying Index , as presently constituted, is designed to track the performance of U.S. securities classified in the USA, according to the MSCI Country of Classification Methodology, included with in the MSCI USA Index that fall within have been designated in the Consumer Discretionary sector by the MSCI and S&P Dow Jones Indices' Global Industry Classification Standard (GICS ® ), based on the MSCI Global X Funds 605 Third Avenue, 43 rd Floor New York, NY 10158 and S&P Dow Jones Indices' Global Industry Classification Standard (GICS ® ) , as determined by MSCI Inc. (“MSCI” or the "Index Provider"). The Underlying Index , which rebalances and is reconstituted on a quarterly basis, implements a free float market capitalization weighting methodology that does not impose without imposing maximum weight constraints on individual securities, which enables greater more exposure to securities classified by GICS ® as Consumer Discretionary companies than would otherwise be possible if maximum weight constraints were imposed (so-called “PureCap” exposure to the Consumer Discretionary sector). Free float market capitalization measures a company’s market capitalization by multiplying the equity’s price by the number of its shares readily available to be traded in the market (“free float”). Rebalancing refers to regular adjustments made to the weights of existing constituents within an index consistent with the methodology of that index, whereas reconstituting refers to the process of adding or removing the constituent securities of an index. The selection of the components of the Underlying Index is made by the Index Provider based on its proprietary methodology. The Fund’s portfolio is generally rebalanced and reconstituted in accordance with the Underlying Index. As part of the investment strategy, the Fund may also invest in ETFs that track the performance of companies within the Consumer Discretionary sector , as classified by GICS ® , or companies that, either individually or in the aggregate, invest in securities that collectively have an investment profile substantially similar to the Underlying Index ’s component securities in terms of key risk factors, performance attributes and other economic characteristics . 5.      Comment : Please disclose how the index is weighted and what a free float market capitalization is. Response : The Registrant has amended the relevant disclosure throughout the registration statement as shown in response to Comment #4. 6.      Comment : Please disclose the implications of the “PureCap”. Response : The Registrant notes that the term “PureCap” refers to the absence of maximum weight constraints on the individual securities included in the Underlying Index, which may result in the Underlying Index, and in turn, the Fund, being highly concentrated in a limited number of Consumer Discretionary companies. As a result, the Fund may be significantly influenced by the performance of those few companies, which may result in heightened volatility. The Registrant respectfully submits that the implications of this approach are appropriately reflected in each Fund’s existing risk disclosure. Please see “ Focus Risk ”, “ Capitalization Risk ”, and their sub-risk Global X Funds 605 Third Avenue, 43 rd Floor New York, NY 10158 factors. The Registrant has also added the following disclosure to “ Focus Risk ” in the section titled “ A FURTHER DISCUSSION OF PRINCIPAL RISKS ” in each Fund’s Summary and Statutory Prospectus: In following its methodology, the Underlying Index may be focused to a significant degree in securities of issuers in a particular industry or group of industries and/or may have significant exposure to one or more sectors. To the extent that the Underlying Index focuses in the securities of issuers in such an area, the Fund will also focus its investments to approximately the same extent. In such event, the Fund’s performance will be particularly susceptible to adverse events impacting such industry or sector, and the Fund will face greater risk than if it were diversified broadly over numerous such areas. Such heightened risks, any of which may adversely affect the companies in which the Fund invests, may include, but are not limited to, the following: general economic conditions or cyclical market patterns that could negatively affect supply and demand; competition for resources; adverse labor relations; political or world events; obsolescence of technologies; and increased competition or new product introductions that may affect the profitability or viability of companies in a particular industry or sector. In addition, at times, such industry, group of industries or sector may be out of favor and underperform other such categories or the market as a whole. The Fund may be susceptible to an increased risk of loss, including losses due to events that adversely affect the Fund’s investments more than the market as a whole, to the extent that the Fund's investments are focused in the securities of a particular issuer or issuers within the same geographic region, market, industry, group of industries, sector or asset class. The “PureCap” exposure of the Fund’s Underlying Index, as described in the Fund’s Principal Investment Strategy, may result in greater exposure to certain individual securities of the Underlying Index and enhance the adverse effects of the risks described above on the Fund’s investments. 7.      Comment : In the last sentence of the third paragraph of the indicated section, please consider deleting the word “substantially”. Response : Please see the Registrant’s response to Comment #4 above. 8.      Comment : In the first sentence of the fourth paragraph of the indicated section, please consider deleting the “As of” qualifier from the beginning of the sentence. If this qualifier is maintained, please explain its importance in correspondence. Global X Funds 605 Third Avenue, 43 rd Floor New York, NY 10158 Response : The Registrant has modified the indicated sentence as follows, and has modified similar statements throughout the registration statement accordingly: As of [ ], As defined by GICS ® , t he Consumer Discretionary sector encompasses… 9.      Comment : Please disclose what consumer discretionary items are, and please explain how they differ from consumer staples. Response : The Registrant has added the below language to the prospectus of the Global X PureCap SM MSCI Consumer Discretionary ETF and similar language to the Global X PureCap SM MSCI Consumer Staples ETF, as shown in response to Comment #22: As defined by GICS® , As of [ ], the Consumer Discretionary sector encompasses " those businesses that tend to be the most sensitive to economic cycles. Its manufacturing segment includes automobiles and components, household durable goods, leisure products and textiles and apparel. The services segment includes hotels, restaurants, and other leisure facilities. It also includes distributors and retailers of consumer discretionary products. " Consumer Discretionary companies are generally understood to sell goods and services that consumers consider non-essential. 10.      Comment : Please disclose the rules-based methodology indicating how index components are determined.      Response : The Registrant notes that each Fund seeks to track the performance of its respective MSCI USA Sector Index. Each MSCI USA Sector Index is constructed using a rules-based methodology developed by MSCI Inc. and is derived from the MSCI USA Index, which includes large- and mid-cap U.S. equities. Index constituents are selected based on their classification within a specific economic sector, as determined by the Global Industry Classification Standard (GICS®). Only securities from the parent MSCI USA Index that fall within the relevant sector are included. The MSCI USA Index is part of the broader MSCI Global Investable Market Index. The Registrant has attached the index methodology document which details the index construction. 11.      Comment : Please disclose how often the index is re-balanced and re-constituted, and please explain the difference between these two terms. Global X Funds 605 Third Avenue, 43 rd Floor New York, NY 10158      Response : The Registrant has modified the indicated sentence as indicated in the response to Comment #4, and has modified similar statements throughout the registration statement accordingly. 12.      Comment : Please disclose why a particular security may be added or deleted.      Response : A company can be added to or removed from a GICS sector through a formal reclassification process typically based on significant changes to its business model, revenue sources, or operational focus. The Registrant has updated the disclosure as indicated in response to Comment #4. 13.      Comment : Given the nature of the Fund’s investments, please explain, in correspondence, how the Fund’s strategy is passive. Response : The Registrant has modified the following language throughout the prospectuses, and removed all references to a “passive” investment approach: The Adviser uses a n “passive” indexing approach to try to achieve the Fund's investment objective. Passive Investment Indexing Strategy Risk: The Fund is generally not actively managed, and the Adviser does not attempt to take defensive positions in declining markets. Unlike many investment companies, the Fund does not seek to outperform its Underlying Index. Therefore, it would not necessarily buy or sell a security unless that security is added or removed, respectively, from the Underlying Index, even if that security generally is underperforming. Additionally, if a constituent of the Underlying Index were removed, even outside of a regular rebalance of the Underlying Index, the Adviser anticipates that the Fund would sell such security. Maintaining investments in securities regardless of market conditions or the performance of individual securities could cause the Fund’s return to be lower than if the Fund employed an active strategy. 14.      Comment : Please revise the 80% policy throughout the registration statement for consistency.      Response : The Registrant has updated the 80% policy in the “ADDITIONAL INFORMATION ABOUT THE FUNDS” as follows: Each Fund invests at least 80% of their net assets, plus the amount of any borrowings for investment purposes (if any), in the securities of its Underlying Index or in investments (either directly or indirectly through exchange-traded funds (“ETFs”)) that have, either individually or in the aggregate, economic characteristics that are similar to the economic characteristics of its Underlying Index’s component securities . Global X Funds 605 Third Avenue, 43 rd Floor New York, NY 10158 GLOBAL X PURECAP MSCI CONSUMER DISCRETIONARY ETF - PROSPECTUS - SUMMARY OF PRINCIPAL RISKS 15.      Comment : Please disclose how investing in leveraged single-stock ETFs and short positions on single-stock ETFs will help the Fund track its index, and please disclose the percentage of the Fund’s assets that will be comprised of such investments. Further, please disclose the underlying security of each such investment. Response : The Registrant notes that the Fund’s objective is to seek to provide the investment results that correspond generally to the price and yield performance, before free and expenses, to its underlying index. To achieve this