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SEC Comment Letter for Global Indemnity Group, LLC (GBLI) (CIK 0001494904) (GBLI) — Jul 5, 2018

Global Indemnity Group, LLC (GBLI) (CIK 0001494904)
Date: July 5, 2018 · CIK: 0001494904 · Accession: 0000000000-18-020612

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File numbers found in text: 333-225758

Date
July 3, 2018
Author
Cynthia Y. Valko
Form
UPLOAD
Company
Global Indemnity Group, LLC (GBLI) (CIK 0001494904)

Letter

July 3, 2018 Cynthia Y. Valko Chief Executive Officer Global Indemnity Limited 27 Hospital Road George Town, Grand Cayman KY1-9008 Cayman Islands Re:Global Indemnity Limited Registration Statement on Form S-3 Filed June 20, 2018 File No. 333-225758 Dear Ms. Valko: We have limited our review of your registration statement to those issues we have addressed in our comments. In some of our comments, 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. If you do not believe our comments apply 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 registration statement and the information you provide in response to these comments, we may have additional comments. Registration Statement on Form S-3 General 1.Please explain how you determined that Global Indemnity Group, Inc. is eligible to register this offering on Form S-3. If you are relying on Instruction I.C of Form S-3, please explain how you meet the requirements set forth in those instructions. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of

FirstName LastNameCynthia Y. Valko Comapany NameGlobal Indemnity Limited July 3, 2018 Page 2 FirstName LastName Cynthia Y. Valko Global Indemnity Limited July 3, 2018 Page 2 action by the staff. Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement. Please contact Ada D. Sarmento at 202-551-3798 or Erin Jaskot at 202-551-3442 with any questions. Division of Corporation Finance Office of Healthcare & Insurance cc: Megan J. Baier, Esq.

Show Raw Text
July 3, 2018
Cynthia Y. Valko
Chief Executive Officer
Global Indemnity Limited
27 Hospital Road
George Town, Grand Cayman
KY1-9008
Cayman Islands
Re:Global Indemnity Limited
Registration Statement on Form S-3
Filed June 20, 2018
File No. 333-225758
Dear Ms. Valko:
            We have limited our review of your registration statement to those issues we have
addressed in our comments.  In some of our comments, 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.  If you do not believe our comments apply 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 registration statement and the information you
provide in response to these comments, we may have additional comments.
Registration Statement on Form S-3
General
1.Please explain how you determined that Global Indemnity Group, Inc. is eligible to
register this offering on Form S-3. If you are relying on Instruction I.C of Form S-3,
please explain how you meet the requirements set forth in those instructions.
            We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action or absence of

 FirstName LastNameCynthia Y. Valko
 Comapany NameGlobal Indemnity Limited
 July 3, 2018 Page 2
 FirstName LastName
Cynthia Y. Valko
Global Indemnity Limited
July 3, 2018
Page 2
action by the staff.
            Refer to Rules 460 and 461 regarding requests for acceleration.  Please allow adequate
time for us to review any amendment prior to the requested effective date of the registration
statement.
            Please contact Ada D. Sarmento at 202-551-3798 or Erin Jaskot at 202-551-3442 with
any questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Megan J. Baier, Esq.