SecProbe.io

July 13, 2011
 Via E-mail

Larry A. Frakes Chief Executive Officer Global Indemnity PLC
Arthur Cox Building
Earlsfort Terrace Dublin 2 Ireland
Re: Global Indemnity PLC
  Registration Statement on Form S-3
Filed July 7, 2011
  File No. 333-175391

Dear Mr. Frakes:
 We have limited our review of your registrati on statement to the issue we have addressed
in our comment.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
 Please respond to this letter by amending your registration statement and providing the
requested information.  Where you do not believe our comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
 After reviewing any amendment to your re gistration statement and the information you
provide in response to this comment, we may have additional comments.

 General

1. We note that you have incorporated by reference the company’s 2010 Form 10-K,
March 31, 2011 Form 10-Q and several curr ent reports on Form 8-K.  However, you
have not incorporated by reference th e Item 8.01 Form 8-K filed April 28, 2011.
Please amend your registration statement to  incorporate by reference the Form 8-K
filed April 28, 2011.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Larry A. Frakes Global Indemnity PLC July 13, 2011 Page 2

Notwithstanding our comment, in the event you request acceleration of the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.  Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Johnny Gharib at (202) 551- 3170 or me at (202) 551-3715 with any
questions.
Sincerely,
   /s/ Jeffrey P. Riedler    Jeffrey Riedler
Assistant Director