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October 21, 2016

Via EDGAR

Mr. Coy Garrison

Special Counsel

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

Washington, D.C. 20549

 Re: Global Net Lease, Inc.

Registration Statement on Form
S-4

Filed September 19, 2016

File No. 333-213691

Dear Mr. Garrison:

We are transmitting for filing the response of Global Net
Lease, Inc. (“GNL”)  to the comments of the Staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) contained in your letter to me dated October 17, 2016 (the “October
17th Letter”) regarding the joint proxy statement/registration statement on Form S-4 (the “Form
S-4”) filed by GNL and American Realty Capital Global Trust II, Inc. (“Global II,” and together with GNL,
the “Companies”). For convenience of reference, the Staff comments contained in the October 17th
Letter are reprinted below in bold type and are followed by the corresponding response of GNL. On October 21, 2016, GNL filed
via EDGAR Amendment No. 1 to the Form S-4 (the “Amendment”). The Amendment reflects the Companies’
responses to the October 17th Letter as well as certain revised and supplemental information. For your
convenience, a marked copy of the Amendment indicating changes against the Form S-4 is being provided to the Staff via
email.

The headings and numbered paragraphs below correspond to the headings
and numbered paragraphs of the October 17th Letter. References to page numbers (other than in headings taken from the
October 17th Letter) are to pages of the Form S-4.

General

 1. We note the disclosure under the caption “Potential Conflicts” on page 110. We also note that cash will be paid
in lieu of fractional shares. Please provide your analysis regarding the applicability of Rule 13e-3 to the merger transaction
given that the exception in Rule 13e-3(g)(2) requires that security holders are offered or receive only an equity security. In
your response, please address: (i) the number of Global II security holders who, giving effect to the merger consideration, would
be subject to cash disposition of fractional interests; (ii) the estimated aggregate amount of cash payable to dispose of fractional
interests; and (iii) the number of Global II security holders, if any, who would be effectively cashed out after giving effect
to the cash disposition of fractional interests. Also, revise your disclosure to describe how the amount of cash to be paid will
be calculated and whether or not there is a maximum amount of cash that will be paid in lieu of fractional shares.

Coy Garrison

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

October 21, 2016

Page 2

As requested by the staff, we have revised the disclosure on page
1 to state that the amount of cash to be paid for fractional interests will equal the product of (i) the fractional part of a share
of GNL common stock due to a Global II security holder, multiplied by (ii) the per share closing price of the GNL common stock
on the closing date of the merger transaction.

As an illustrative example, please assume that a Global II security
holder owns one share of Global II common stock and the closing price of GNL common stock on the closing date is equal to $7.75
per share, which was the closing price on October 19, 2016. Based on the exchange ratio of 2.27, the security holder will receive
two shares of GNL common stock and $2.09 in cash. The amount of cash is equal to the product of (i) the fractional interest of
0.27, multiplied by (ii) the per share price of $7.75.

For the reasons set forth below, we do not believe that Rule 13e-3
applies to the merger transaction between GNL and Global II.

The Exception in Rule 13e-3(g)(2) Should Apply to the Merger
Transaction

Below is the information requested by the staff with respect to
the cash payment for fractional shares:

 · At October 19 2016 there were approximately 6,322 Global II security holders. We expect that a substantial majority, and even
perhaps all, of these holders may be subject to cash disposition of fractional interests. The exact number of holders depends on
the number of Global II shares a holder owns and, after giving effect to the exchange ratio of 2.27, the number of GNL shares such
holder is due to receive.

 · Based on (i) the closing price of GNL common stock of $7.75 per share on October 19, 2016 and (ii) 12,512,087 shares
                                                                                                               of outstanding Global II common stock on October 19, 2016, the
                                                                                                               estimated
                                                                                                               maximum
                                                                                                               aggregate
                                                                                                               amount                                                                                                                of
                                                                                                               cash                                                                                                                payable
                                                                                                               to                                                                                                                dispose
                                                                                                               of                                                                                                                fractional
                                                                                                               interests                                                                                                                is
                                                                                                               $17,588. GNL has not imposed a cap on the amount of cash that will be paid in lieu of fractional shares, and the
                                                                                                               aforementioned formula reflects the  amount of cash that would be paid, but the amount of cash is not likely to be
                                                                                                               materially                                                                                                                in
                                                                                                               excess of this estimate.

 · No Global II security holders will be effectively cashed out after giving effect to the cash disposition of fractional interests
because every Global II security holder holds at least one share of Global II common stock and, based on an exchange ratio of 2.27,
will receive at least two shares of GNL common stock.

As indicated by the numbers above, the cash that will be paid to
dispose of fractional interests represents a de minimis amount of the total merger consideration valued at approximately
$222.3 million.1 Except for cash payments for fractional
interests, all of the merger consideration will consist of GNL common stock, a class of security that satisfies the conditions
in Rule 13e-3(g)(2)(i)-(iii).

In adopting Rule 13e-3, the Commission stated that
transactions covered by the exception in paragraph (g)(2) are “outside the purpose of Rule 13e-3 since all holders of
that class of security are on an equal footing and are permitted to maintain an equivalent or enhanced equity
interest.”2 We do not believe that the
presence of a de minimis amount of cash paid for fractional interests contravenes this purpose. All Global II security
holders will continue to be security holders of GNL. GNL common stock represents at least an equivalent equity interest, and
likely an enhanced equity interest to these security holders because it is listed on a national securities exchange, whereas
Global II common stock is not. Global II security holders who are due fractional interests will receive a cash amount equal
to the closing market price of GNL common stock on the closing date for their fractional interests, which is clearly an
equivalent value to the fractional interests they are due. Both affiliated and unaffiliated Global II security holders
will receive cash for their fractional interests, so there is no disparate treatment between the two groups. In viewing the
transaction in its totality, Global II security holders are afforded equal treatment both among themselves and in their
receipt of GNL common stock, which is at least an equivalent equity interest as Global II common stock. The payment of a de
minimis amount of cash for fractional interest to Global II security holders, when all Global II security holders will
continue as GNL security holders , does not undermine the purposes behind the exemption. The fractional interests could have
been determined by eliminating the fractional interests or rounding the fractional interest up to the nearest whole number,
and payment of cash for the fractional interest should not change the result.

1
Based on (i) the closing price of GNL common stock of $7.75 per share on October 19, 2016 and (ii) 12,512,087 shares of outstanding
Global II common stock on October 19,2016.

2
Release 34-16075 (August 2, 1979).

Coy Garrison

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

October 21, 2016

Page 3

The staff has previously granted no-action relief for reliance on
Rule 13e-3(g)(2) on facts involving the payment of cash in lieu fractional shares to the target’s security holders.3
In each of the cited no-action letters, the incoming request referenced the payment of cash in lieu of fractional shares to the
target’s security holders. While the discussion relating to the availability of the exception did not focus on the presence
of this cash payment, the staff did grant relief from Rule 13e-3 on the basis of the exception contained in paragraph (g)(2).

No Affiliates of Global II are Engaged in the Merger Transaction

For Rule 13e-3 to apply to the merger transaction, an affiliate
of Global II must be engaged in the merger transaction. For the reasons set forth below, we do not believe that this requirement
is satisfied.

GNL and Global II are not affiliates

A person is an affiliate of Global II if it directly or indirectly
controls, is controlled by or is under common control with Global II. Control means direct or indirect possession of the power
to direct or cause the direction of the management and policies of a person. GNL does not directly or indirectly own any voting
securities of Global II, and vice versa. Additionally, GNL does not directly or indirectly have any contractual arrangements that
permit it to direct the management and policies of Global II, and vice versa. As a result, GNL neither controls nor is controlled
by Global II. Accordingly, the only way that GNL and Global II can be affiliates is if they are deemed to be under common control.

As the staff notes, GNL and Global II share several relationships,
which are disclosed in “Potential Conflicts” on pages 18 and 111. While we believe that these relationships may be
material information for investors in making an investment decision and have therefore disclosed them, we do not believe that these
relationships, individually or in the aggregate, cause GNL and Global II to be under common control.

GNL has a board of directors consisting of four people. Three of
these directors, constituting a majority, are independent pursuant to the listing standards of the New York Stock Exchange. Similarly,
Global II has a board of directors consisting of three people, and a majority of the board (or two directors) are independent pursuant
to the criteria set forth in Global II’s charter. The board of each of GNL and Global II has ultimate control over each entity,
including the ability to elect and remove officers for each entity. GNL and Global II do not have any directors in common. Furthermore,
the independent directors of GNL have no relationships that enable them to exert control over Global II, and vice versa. Accordingly,
GNL and Global II are not under common control due to the fact that no person or governance body has the direct or indirect power
to cause the direction of the management and policies of both entities. Rather, GNL and Global II operate independently of each
other under the ultimate supervision of their respective boards.

3
See, e.g., Canadian Pacific Limited (June 26, 1996), Standard Shares, Incorporated (April 28, 1989) and Swanton
Corporation (November 26, 1984).

Coy Garrison

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

October 21, 2016

Page 4

As disclosed in “Potential Conflicts,” Messrs. Bowman
and Salvemini serve as Chief Executive Officer and Chief Financial Officer, respectively to each of GNL and Global II. We do not
believe that the presence of overlapping officers causes GNL and Global II to be under common control. Each of Messrs. Bowman and
Salvemini is an employee of the respective advisor to GNL and Global II, or its affiliate, and each respective board GNL or Global
II, as the case may be, can terminate either person’s position as an officer at any time. Additionally, decisions by Messrs.
Bowman and Salvemini that would affect the management and policies of both GNL and Global II are subject to board oversight and
approval. Furthermore, each of Messrs. Bowman and Salvemini beneficially owns less than one percent of each of GNL and Global II.
Accordingly, Messrs. Bowman and Salvemini do not cause GNL and Global II to be under common control because they cannot, individually
or together, direct the management and policies of both GNL and Global II through their positions (in light of the board oversight)
or share ownership.

Also as disclosed in “Potential Conflicts,” the advisor
to each of GNL and Global II is ultimately controlled by AR Global, the sponsor to GNL and Global II. We do not believe that having
the same sponsor or advisors controlled by the same sponsor causes GNL and Global II to be under common control for two reasons.
First, AR Global beneficially owns less than one percent of each of GNL and Global II. This low percentage supports the conclusion
that AR Global cannot direct the management and policies of both entities through its share ownership. Second, while an AR Global-affiliated
advisor manages the day-to-day operations of each of GNL and Global II, each advisor’s actions are subject to the supervision
and direction of each entity’s board This board oversight supports the conclusion that AR Global cannot direct the management
and policies of both entities through its indirect contractual arrangements.

While one director of the board of each of GNL and Global II is
an affiliate of AR Global, we do not believe that the presence of this one director on each board changes the foregoing conclusion
that GNL and Global II are not under common control. The one AR Global-affiliated director is the lone member of each board who
is not independent and he cannot effect board action by himself.

Messrs. Bowman and Salvemini are not affiliates engaged in the
merger transaction

As the Chief Executive Officer and Chief Financial Officer of Global
II, Messrs. Bowman and Salvemini, respectively, may be deemed affiliates of Global II. The merger transaction was negotiated by
special committees of independent directors of each of GNL and Global II and not by the executive