SecProbe.io

August 8 , 201 2

Via E -mail
Ms. Cynthia Y. Valko
Chief Executive Officer
Global Indemnity plc
Arthur Cox Building
Earlsfort Terrace
Dublin 2, Ireland

Re: Global Indemnity plc
 Form 10-K for the Fiscal Year Ended December 31, 2011
   Filed March 14 , 201 2
   Form 10 -Q for the Quarterly Period Ended March 31, 2012
   Filed May 10, 2012
File No. 001-34809

Dear Ms. Valko :

We have reviewed your filing s and have the following comments.  In our comments, we
ask you to provide us with information so we may better understand your disclosure.

Please respond to this letter within 10 business days by providing us the requested
information or by advising us wh en you will provide the requested response.  If you do not
believe a comment applies to your facts and circumstances, please tell us why in your response.
Please furnish us a letter on EDGAR under the form type label CORRESP that keys your
responses to ou r comments.

After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing s.

Form 10 -K for the Fiscal Year Ended December 31, 2011

General

1. We note that throughout your filing you provide information  primarily by your insurance and
reinsurance segments. For example you provide quantitative information such as gross and
net premiums written, net premiums earned, income or loss from underwriting, loss ratio,
expense ratio and combined ratio as well as q ualitative information related to these measures
on a segmental basis. Please consider also providing information by material product lines  or
groups of similar  or related product lines  in future periodic reports and advise us as to your
conclusions. Tell us what specific information you could provide  on a product line basis  or
product line group basis . In responding to this comment please consider and address the

Ms. Cynthia Y. Valko
Glob al Indemnity plc
August 8 , 2012
Page 2

 extent to which information by product line  or product line groups may be material to
investors and how you have organized and conduct your business operations. In that regard
we note that th e transcript of your earnings call for the fiscal year ended December 31, 2011
indicates substantial interest in how the various product lines you offer affected your
financial results for fiscal 2011.

Exhibits

2. The disclosure in your definitive proxy statement for your 2012 Annual General Meeting of
Shareholders indicates that you have entered into employment agreements with Ms. Valco
and Messrs. Lebens and Devlin. Please amend your 10 -k to file these agreements as exhibits.

Financial Statements
Note 10 Income Taxes, page 123

3. You disclose current foreign and U.S. federal income tax expense  (benefit)  of $2.6 million,
$5.4 million and $(5.3) million in 2011, 2010 and 2009, respectively.  Provide us with
proposed d isclosure to be included in future periodic reports that shows current income tax
expense (benefit) of foreign and U.S. federal separately in accordance with Rule 4 -08(h) of
Regulation S -X.  If foreign current income tax expense is less than 5% of total cu rrent
income tax expense for all periods, disclose that fact.

Note 11 Liability for Unpaid Losses and Loss Adjustment Expenses, page 126

4. When explaining increases and decreases in prior year loss reserves you aggregate multiple
loss years.  For example, for 2011 professional liability you state “The $4.4 million increase
primarily related to our Insurance Operations and consisted of increases of $19.0 million
related to accident years 1998, 2009 and 2010, offset partially by decreases of $13.2 million
related to all other accident years.”  Provide us with proposed disclosure to be included in
future periodic reports that disaggregates all increases and decreases discussed by accident
year or tell us why you do not believe additional disclosure is warranted .  Ensure your
disclosure also explains the underlying cause of the change, and that it clarifies the timing of
the change in estimate such as why recognition occurred in the periods that it did and why
recognition in earlier periods was not required.  Exp lain, for example, why you reduced
general liability reserves for the 2009 accident year in 2010 and then increased reserves for
the 2009 accident year in 2011.

Form 10 -Q for the Quarterly Period Ended March 31, 2012
Note 7 Income Taxes, page 24

5. Regarding the tax rate reconciliation, explain in proposed disclosure to be included in future
periodic reports why the line item “effective tax rate adjustment” results in a reduction of
$2.6 million in 2012 as compared to an increase of $1.5 million in 2 011.  Explain why the

Ms. Cynthia Y. Valko
Glob al Indemnity plc
August 8 , 2012
Page 3

 effective tax rate in 2012 is a 33.2% benefit  on income  before tax when your effective tax
(benefit) rates in 2011, 2010, and 2009 were (5.6%), 9.5%, and 5.8%.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a compa ny’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

In responding to our comment s, please provide a written statement from the company
acknowledging that:
 the company is responsible for the adequacy and  accuracy of the disclosure in the filing s;
 staff comment s or changes to disclosu re in response to staff comment s do not foreclose
the Commission from taking any action with respect to the filing s; and
 the company may not assert staff comment s as a defense  in any proceeding initia ted by
the Commission or any person under the federal securities laws of the United States.

You may contact Tabatha Akins, Staff Accountant, at (202) 551 -3658 or Lisa Vanjoske,
Assistant Chief  Accountant, at (202) 551 -3614 if you have any questions regarding the
processing of your response as well as any questions regarding comments on the financial
statements and related matters.   Please contact Nandini Acharaya,  Attorney Advisor, at (202)
551-3495  or Jeffrey Riedler, Assistant Director, at (202) 551 -3715 with questions on comments
one and two .  In this regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

  /s/ Joel Parker for

Jim B. Rosenberg
Senior Assistant Chief Accountant