SecProbe.io

December 23, 2014

Via E-mail
Mr. Thomas M. McGeehan
Chief Financial Officer
Global Indemnity plc
28/28 North Wall Quay
Dublin Ireland

Re: Global Indemnity plc
Form 10-K for the Fiscal Year Ended December 31, 2013
Filed March 1 4, 2014
File No . 001-34809

Dear Mr. McGeehan :

 We have limited our review of your filing  to your financial statements and related
disclosures and do not intend to expand our review to other portions of your document .  In some
of our comment s, 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  amending your filing , providing
the requested information or by advising us when 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 response s to our comment s.

After reviewing any amendment to your filing and the information you provide in
response to these comments , we m ay have additional comments .

Report of Independent Registered Public Accounting Firm, page 89

1. Include  the name of the auditor on the auditor’s report.

Notes to Consolidated Financial Statements
20. Statutory Financial Information, page 141

2. Please revise  to address the following:
 If you did not significantly exceed  all of the  requirements  you disclose on page 142 for
your U.S. insur ance subsidiaries , include the  disclosure required by ASC 944 -505-50-1b.
Provide similar information for Wind River Reinsurance , as applicable .
 Disclose the amount of retained earnings or net income that is restricted or free of
restrictions for payment of dividends by Global Indemnity plc to  its  stockholders as
required by Rule 4 -08(e)(1) of Regulation S -X.

Mr. Thomas M. McGeehan
Global Indemnity plc
December 23, 2014
Page 2

  Disclose the amount of statutory net i ncome or loss  and statutory capital and surplus of
Wind River Reinsurance  for each period .  Refer to  Rule 7 .03(a)(23)(c) of Regulation S -X
and ASC 944 -505-50-1a.
 Provide the disclosures required under ASC 944 -505-50-2 through 50 -6, as applicable.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing  to be certain that the filing  include s the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules req uire.  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 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 ;
 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from tak ing 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.

You may contact Senior Staff Accountants Christine Torney  at (202) 551 -3652 or  Mary
Mast  at (202) 551 -3613 if you have questions regarding the comments .  In this regard, do not
hesitate to contact me at (202) 551 -3679.

Sincerely,

/s/ Jim B. Rosenberg

Jim B. Rosenberg
Senior Assistant Chi ef Accountant