SecProbe.io

CORRESP
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Brian London

Associate

215-963-5886

brian.london@morganlewis.com

June 29, 2020

FILED AS EDGAR CORRESPONDENCE

Anu Dubey, Esq.

U.S. Securities and Exchange Commission

100 F Street, NE

Washington, D.C. 20549

 Re: Gallery Trust 485(a) Filing (File Nos. 333-206713
and 811-23091)

Dear Ms. Dubey:

On behalf of our client, Gallery Trust (the
"Trust"), this letter responds to the comments provided on behalf of the staff (the "Staff") of the Securities
and Exchange Commission (the "SEC") via telephone, regarding the Trust's post-effective amendment no. 20, under the Securities
Act of 1933, as amended (the "1933 Act"), and amendment no. 23, under the Investment Company Act of 1940, as amended
(the "1940 Act"), to its registration statement filed with the SEC pursuant to Rule 485(a) under the 1933 Act (the "Amendment")
with respect to the Mondrian Global Equity Value Fund (the "Fund"). Below, we have briefly summarized your comments and
questions, followed by our responses. Where indicated, certain of the responses are based on information provided by Mondrian Investment
Partners Limited (the "Adviser"), the investment adviser of the Fund, for the specific purpose of responding to the Staff's
comments. Capitalized terms not defined herein should be given the meaning provided in the Amendment.

Comments on the Prospectus

 1. Comment.	The Cover Page of the Prospectus states that shareholders investing through
a financial intermediary can follow the "instructions included with this disclosure, if applicable" if they wish to continue
receiving paper copies of their shareholder reports, or they can contact their financial intermediary. Please update the disclosure
to clarify where the "instructions included with this disclosure" are located.

Response. The referenced disclosure has been revised as follows:

You may elect to receive all future reports in paper free of charge. If you invest through a financial intermediary, you can follow
the instructions included with this disclosure, if applicable
provided below for direct investors, or you can contact your financial intermediary to inform it that you
wish to continue receiving paper copies of your shareholder reports. If you invest directly with the Fund, you can inform the
Fund that you wish to continue receiving paper copies of your shareholder reports by calling 888-832-4386. Your election to receive
reports in paper will apply to all funds held with your financial intermediary if you invest through a financial intermediary
or all funds in the Gallery Trust if you invest directly with the Fund.

 2. Comment.	Please confirm supplementally whether the Adviser may recoup all or a
portion of its prior fee waivers or expense reimbursements pursuant to its expense limitation agreement with the Trust and, if
so, please add appropriate disclosure to the second footnote to the "Annual Fund Operating Expenses" table.

   Morgan, Lewis & Bockius llp

   1701 Market Street

   Philadelphia, PA  19103-2921

   United States

    +1.215.963.5000

     +1.215.963.5001

Anu Dubey, Esq.

June 29, 2020

Page 2

Response.
	The Trust confirms that the Adviser may not recoup waived fees and/or reimbursed expenses pursuant to the Expense Limitation
Agreement.

 3. Comment.	The second paragraph under the "Principal Investment Strategies"
section states that one criterion the Fund will use to determine whether a company is a non-U.S. company is if the company, "while
traded in any market, alone or on a consolidated basis, derives 50% or more of its annual revenues or annual profits from
either goods produced, sales made or services performed outside of the U.S. (emphasis added)". Please explain why it is appropriate
to meet this criterion on a consolidated basis.

Response.	The Financial
Accounting Standards Board ("FASB") stated in "Accounting Research Bulletin 51: Consolidated Financial Statements"
that the purpose of consolidated statements is to present, primarily for the benefit of the shareholders and creditors of the parent
company, the results of operations and the financial position of a parent company and its subsidiaries essentially as if the group
were a single company with one or more branches or divisions. The Trust notes that the Fund may invest in securities of a parent
company that operates through its subsidiaries and therefore issues consolidated financial statements. The Trust respectfully submits
that it believes it is reasonable that such consolidated financial statements would be used to determine the annual revenues and
earnings of the parent company and from what country or countries such revenue or earnings were derived. The Trust also notes that
a subsidiary company in which the Fund may invest would not meet this criterion based on a combination of its and its parent company's
earnings and revenues, and further notes that the referenced language in the Fund's prospectus is not intended to refer to subsidiary
companies in which the Fund may invest, on a consolidated basis with its parent company. In order to clarify this point in the
disclosure and avoid any confusion regarding the use of these terms in the future, the Trust has revised the disclosure to replace
the phrase "alone or on a consolidated basis" with "alone or, with respect to a parent company, on a consolidated
basis with its subsidiaries".

 4. Comment.	 Please confirm that the fees and expenses incurred indirectly by the
Fund as a result of its investment in shares of one or more acquired funds are not expected to exceed 0.01 percent of the average
net assets of the Fund during the current fiscal year or alternatively, add an "Acquired Fund Fees and Expenses" subcaption
to the Fund's "Annual Fund Operating Expenses" table and disclose in the subcaption the estimated fees and expenses expected
to be incurred indirectly by the Fund as a result of its investment in shares of one or more acquired funds during the current
fiscal year.

Response.	The
fees and expenses incurred indirectly by the Fund as a result of its investment in shares of one or more other funds are not expected
to exceed 0.01 percent of the average net assets of the Fund during the current fiscal year.

 5. Comment.	In the "Principal Investment Strategies" section, please disclose
that, for purposes of the Fund's 80% investment policy, equity securities do not include convertible securities that are not immediately
convertible into equity securities.

Anu Dubey, Esq.

June 29, 2020

Page 3

Response.	The
requested change has been made.

 6. Comment.	Please confirm that the Fund does not expect to invest in contingent
convertible securities as part of its principal investment strategies or, alternatively, add appropriate disclosure to the "Principal
Investment Strategies" and "Principal Risks" sections.

Response.	The
Adviser confirms that it does not currently expect investments in contingent convertible securities to be part of the Fund's principal
investment strategies.

 7. Comment.	In
the "Principal Investment Strategies" section, please disclose that the Fund will consider any investments in unregistered
funds to be illiquid securities.

Response.
	 Although the Fund may invest in unregistered funds, the Fund does not currently intend to invest in unregistered funds as
part of its principal investment strategy; accordingly, references to unregistered funds have been removed.

 8. Comment.	In the "Principal Investment Strategies" section, please (i)
disclose the types of unregistered funds in which the Fund will invest as part of its principal investment strategies; and (ii)
confirm supplementally the percentage of the Fund's net assets that is expected to be invested in unregistered funds.

Response.
	 Although the Fund may invest in unregistered funds, the Fund does not currently intend to invest in unregistered funds as
part of its principal investment strategy; accordingly, references to unregistered funds have been removed.

 9. Comment.	Please explain supplementally how derivatives will be valued for purposes
of the Fund's 80% investment policy.

Response.	The
Fund intends to take into account exposures created by derivative instruments for purposes of its 80% investment policy in a manner
consistent with Rule 35d-1 under the 1940 Act. For example, if a derivative creates an investment exposure to an issuer in an amount
equal to the mark-to-market value of the derivative, the Fund would typically expect to use that value for purposes of its 80%
investment policy. On the other hand, if a derivative creates an investment exposure equivalent to a cash investment in the underlying
issuer equal to the derivative's notional amount, the Fund reserves the right to use that amount for purposes of its 80% investment
policy. The Trust respectfully submits that such treatment is consistent with the SEC's statement in footnote 13 of the adopting
release for Rule 35d-1 (Release No. IC-24828) that "[i]n appropriate circumstances" a fund could "include a synthetic
instrument in the 80% basket if it has economic characteristics similar to the securities included in that basket."

 10. Comment.	Under the "Principal Investment
Strategies" section please consider 	moving the following disclosure to the "More Information about the Fund's Investment
	Objective and Strategies" section:

Anu Dubey, Esq.

June 29, 2020

Page 4

The Fund considers
a company to be an emerging market company if: (1) the company's principal securities trading market is in an emerging market country;
(2) while traded in any market, alone or on a consolidated basis, the company derives 50% or more of its annual revenues or annual
profits from either goods produced, sales made or services performed in emerging market countries; (3) the company has 50% or more
of its assets located in an emerging market country; or (4) the company is organized under the laws of, and has a principal office
in, an emerging market country.

Response.	In
response to this comment, the referenced disclosure has been removed from the "Principal Investment Strategies" section.
However, the Trust notes that the referenced disclosure is already included in the "More Information about the Fund's Investment
Objective and Strategies" section. Accordingly, no changes have been made to that section in response to this comment.

 11. Comment.	Please confirm supplementally whether the Fund currently expects to focus
its investments in a particular country or geographic region. If so, please add appropriate risk disclosure regarding that particular
country or geographic region.

Response.	The
Fund does not currently expect to focus its investments in any 	particular country or region.

 12. Comment.	The Staff notes that the "Market Risk" paragraph in the "Principal
Risks" section discusses the impact of pandemics generally on the Fund and its investments. Given the significant market events
that have occurred as a result of the COVID-19 pandemic since the Trust filed the Amendment, please consider whether more specific
risk disclosure in the Prospectus should be revised based on how the COVID-19 pandemic could affect the Fund and its investments.
If the Trust believes no additional disclosure is warranted, please explain supplementally why not.

Response.	The
Trust notes that the "Market Risk" paragraph in the "More Information about Risk" section discusses more specifically
the impact of COVID-19 on the Fund and its investments. Accordingly, the Trust respectfully believes that its current risk disclosure
adequately addresses the risks to the Fund related to COVID-19.

 13. Comment.	Please confirm supplementally whether the Fund currently expects to invest
in private REITs as part of its principal investment strategies and, if so, whether the Fund's investments in private REITs will
treated as illiquid.

Response.	The
Fund does not currently expect to invest in private REITs as part of its 	principal investment strategies.

 14. Comment.	With response to the Fund's investments in MLPs, please consider disclosing
the risks of investing in companies in the energy industries.

Response.	The
requested change has been made.

Anu Dubey, Esq.

June 29, 2020

Page 5

 15. Comment.	Please confirm supplementally the broad-based securities market index
that will be included in the Fund's "Performance Information" section once the Fund has completed a full calendar year
of operations.

Response.	The
MSCI All Country World Index is the broad-based securities market index that will be included in the Fund's "Performance Information"
section once the Fund has completed a full calendar year of operations.

 16. Comment.	 The second paragraph in the "More Information about Fund Investments"
section states that "during unusual economic or market conditions, or for temporary defensive or liquidity purposes, the Fund
may invest up to 100% of its assets in cash, money market instruments or other cash equivalents that would not ordinarily be consistent
with its investment objective." Please explain how this disclosure is consistent with Instruction 6 to Item 9(b)(1) of Form
N-1A.

Response.	Instruction
6 to Item 9(b)(1) of Form N-1A requires that the Fund "disclose, if applicable, that it may, from time to time, take temporary
defensive positions that are inconsistent with the Fund's principal investment strategies" and further disclose "the
effect of taking such temporary defensive positions (e.g., that the Fund may not achieve its investment objective)." The Trust
believes that the Fund's discussion of investments that may be made for "temporary defensive purposes," and the statement
that the Fund will not achieve its investment objective if it invests in this manner, are expressly permitted by this Instruction.

In addition, the
Trust believes that the Fund's remaining disclosure regarding investments that may be made "during unusual economic or market
conditions … or for liquidity purposes" is permitted by General Instruction C.3(b) to Form N-1A, as it is not incomplete,
inaccurate, or misleading and does not impede or obscure the understanding of the information that is required to be included in
the prospectus. In contrast, the Trust believes that this disclosure is helpful to investors because it provides additional information
regarding investments that may be made by the Fund from time to time under certain conditions.

 17. Comment.	The fifth paragraph of the "Investment Adviser" section states
that the Adviser may reduce advisory fees for shareholders that have an investment advisory relationship with the Adviser by an
amount equal to the shareholder's pro rata share of the advisory fees paid by the Fund. The Staff is concerned that such shareholders
may be subject to a lower management fee with respect to the Fund than shareholders who do not have an investment advisory relationship
with the Adviser. Please remove this disclosure or clarify that the fee reduction discussed in this paragraph is made at the separate
account level, not at the Fund level.

Response.	The
referenced paragraph addresses the reduction of investment advisory fees that may be made by the Adviser for shareholders at the
separate account level, not at the Fund level, by an amount equal to the shareholder's pro rata share of the advisory fees paid
by the Fund. The purpose of this fee reduction at the separate account level is to avoid "double dipping" by the Adviser
and to ensure that a separate account client does not pay higher total advisory fees as a result of such client's investment in
the Fund (i.e. once at the separate account level and once at the Fund level). The fact that the Adviser may waive a portion of
its advisory fee at the separate account level in order to prevent a client from incurring higher total advisory fees as a result
of the client's investment in the Fund does not change the fact that the management fee charged by the Fund is the same for all
Fund investors, nor does it