SecProbe.io

September 26 , 2012

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, 2012
File No. 001 -34809

Dear Ms. Valko :

We have reviewed your filing  and your supplemental response  and have the following
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 within ten busines s days by providing the requested
information, or by advisi ng us when you will provide the requested response.   If you do not
believe our comment  applies to your facts and circumstance s, please tell us why in your
response.

After reviewing  the information you provide in response to our comment , we may have
additional comments.

General

1. We note your response to our prior Comment 1 regarding disclosure of quantitative
information by product line or groups of similar products.   In your Business section, you
mention property, casualty, professional lines and general liability and in your MD&A
section you also mention automobile liability, worker’s compensation and umbrella
product lines.  As we previously noted, the transcript of your earnings call for the fiscal
year en ded December 31, 2011 indicates substantial interest in how the various product lines
you offer affected your overall financial results for fiscal 2011 . While it may not be feasible
to disclose profitability by product line or groups of similar products, a s you have indicated
that operating profitability is distinctly measured at the segment level, please consider
reporting revenue -related information by product line or groups of similar products.   In
this regard, please tell us what further information you  may be able to include in future

Cynthia Y. Valko
Global Indemnity plc
September 26 , 2012
Page 2

 filings to present investors with a clearer picture of the revenue -generating performance
of your various product lines  and provide us with proposed disclosure for future filings .

We urge all persons who are responsible  for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes 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 company’s disclosure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

 In responding to our comments, 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;

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respect to the filing; and

 the company may not  assert staff comments as a defense in any proceeding initiated by
the Commission or any person under the federal securities laws of the United States.

Please contact Nandini Acharya  at (202) 551 -3495  or me at (202) 551 -3715  with any
questions.

Sincerely ,

 /s/ Jeffrey P. Riedler

 Jeffrey P. Riedler
Assistant Director