SecProbe.io

CORRESP
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May 23, 2025

VIA EDGAR TRANSMISSION

Deborah O’Neal, Esq.

Securities and Exchange Commission

Division of Investment Management

100 F Street, N.E.

Washington, D.C. 20549-0506

Re: Grandeur Peak Global Trust, File Nos. 333-269914 and 811-23852 (“Registrant”)

Dear Ms. O’Neal:

On March 17, 2025, the Registrant, on behalf of its
proposed series, Grandeur Peak International Contrarian Fund (the “Fund”), filed an registration statement under the Securities
Act of 1933 on Form N-1A. On April 30, 2025 you provided comments to the amended registration statement. Below, please find those comments
and the Registrant’s responses, which the Registrant has authorized Thompson Hine LLP to make on its behalf. Please note that added
language is in italics and deleted language appears struck through.

Comment 1: Please supplementally provide a
completed Fee Table and Example. Be sure to include a footnote to the Fee Table that “Other Expenses” are estimated.

Response: The completed Fee Table and Example
are shown below:

    Shareholder
    Fees (fees paid directly from your investment)

    Institutional

    Shares

    Redemption
    Fee (as a percentage of or amount redeemed within 60 days of purchase)

    2.00%

    Annual
    Fund Operating Expenses (expenses that you pay each year as a percentage of the value of your investment)

    Management Fees
    1.00%

    Distribution and service (12b-1) fees
    0.00%

    Other
    Expenses(1)

    0.53%

    Total Annual
    Fund Operating Expenses

    1.53%

    Fee Waiver
    and Expense Reimbursement(2)

    (0.18)%

    Total Annual
    Fund Operating Expenses After Fee Waiver/Expense Reimbursement

    1.35%

    Philip.Sineneng@ThompsonHine.com     Direct:  614.469.3217

Deborah O’Neal, Esq.

May 23, 2025

Page 2

(1)       Estimated for the current year.

(2)       Grandeur
Peak Global Advisors, LLC (the “Adviser”), has contractually agreed to waive and/or reimburse fees or expenses in order to
limit Total Annual Fund Operating Expenses After Fee Waiver/Expense Reimbursement (excluding acquired fund fees and expenses, brokerage
expenses, interest expenses, taxes and extraordinary expenses) to 1.35% of the Fund’s average daily net assets for the Fund’s
Institutional Class Shares. This agreement (the “Expense Agreement”) is in effect through September 1, 2026. The Adviser will
be permitted to recapture expenses it has borne through the Expense Agreement to the extent that the Fund’s expenses in later periods
fall below annual rates set forth in the Expense Agreement; provided, however, that such recapture payments do not cause the Fund’s
expense ratio (after recapture) to exceed the lesser of (i) the expense cap in effect at the time of the waiver and (ii) the expense cap
in effect at the time of the recapture. Notwithstanding the foregoing, the Fund will not pay any such deferred fees and expenses more
than three years after the date on which the fee and expenses were deferred. The Expense Agreement may not be terminated or modified prior
to September 1, 2026, except with the approval of the Trust’s Board of Trustees.

EXAMPLE

This example helps you compare the costs of investing in the Fund with the cost of investing in other mutual funds. The example
assumes that you invest $10,000 in the Fund for the time periods indicated and then redeem all of your shares at the end of those periods.
The example also assumes that your investment has a 5% return each year and that the Fund's operating expenses remain the same.

    Although your actual costs may be
    higher or lower, based on these assumptions your cost would be:

    1 Year

    3 Years

    Institutional Shares
    $137
    $447

Comment 2: Please reconcile the Item 4 principal
investment strategy disclosure that the “Fund invests primarily in foreign small and micro-cap companies” with the Item 9
principal investment strategy disclosure that “the Fund invests primarily in foreign and domestic small and micro-cap companies.”

Response: The Registrant will amend its Item
9 disclosures to match its Item 4 disclosure that the “Fund invests primarily in foreign small and micro-cap companies.”

Comment 3: Will the Fund invest in mid-cap
companies as a principal investment strategy?

Response: The Registrant has confirmed with
the adviser that investment in mid-cap companies is not a principal investment strategy of the Fund. The Registrant has deleted “Mid-Cap
Company Stock Risk” from its principal investment risk disclosures.

Comment 4: Does the Fund intend to invest in
contingent convertible securities? If so, please explain supplementally the extent to which it intends to do so.

Response: The Registrant has confirmed that
the Fund does not intend to invest in contingent convertible securities.

Comment 5: Footnote 42 to Rule 35d-1 states
in relevant part: “The terms ‘international’ and ‘global,’ however, connote diversification among investments
in a number of different countries throughout the world, and ‘international’ and ‘global’ funds will not be subject
to the rule. We would expect, however, that investment companies using these terms in their names will invest their assets in investments
that are tied economically to a number of countries throughout the

Deborah O’Neal, Esq.

May 23, 2025

Page 3

world. See Proposing Release, supra note 7, at 10960
n.38 and accompanying text.” Please consider revising the Fund’s disclosures to state that the Fund anticipates investing
in securities that are tied to “a number of” countries or to “multiple” countries to be consistent with this footnote.

Response: The Registrant has amended its Item
4 disclosures to state the following:

Strategic Focus

The Fund invests primarily in foreign
small- and micro-cap companies. Under normal market conditions, the Adviser invests the Fund’s assets primarily in equity securities
(including common stock, preferred stock, and securities convertible into common stock) of foreign companies with market
capitalizations of less than $5 billion at the time of purchase.

The Fund primarily invests in companies
which the Adviser believes are trading at particularly attractive valuations relative to their long-term potential. The companies
typically fall into one of these categories at the time or purchase:

 · “Core
Contrarian”—what the Adviser believes to be best-in-class growth companies, but which are part of a currently out-of-favor
industry, sector, or geography.

 · “Fallen
Angels”—high quality growth companies that the Adviser believes have hit a temporary setback relative to their long-term growth
potential.

 · “Undiscovered
Gems”—smaller growth companies that the Adviser believes are undervalued because they are lesser known, have high product
or client concentration, or are otherwise not well understood yet by the market.

The Fund may also invest in companies
that do not fit into one of these three categories, but which the Adviser believes are trading at attractive valuations with potential
returns consistent with the objective of the Fund. The Fund may invest in early-stage companies and Initial Public Offerings (IPOs).

The Fund invests a significant portion
of its total assets (at least 80% under normal market conditions) at the time of purchase in securities issued by companies that are economically
tied to a number of countries outside the United States. The Adviser considers a company to be economically tied to a country if
at least one of the following attributes exists: the company (1) is organized in such country, (2) is headquartered in such country, (3)
has its primary stock exchange listing in a

Deborah O’Neal, Esq.

May 23, 2025

Page 4

market located in such country, or
(4) during the company’s most recent fiscal year, derived at least 50% of its revenues or profits from goods produced or sold, investments
made, or services performed in such country or has at least 50% of its assets in such country. The Fund may invest a significant amount
of its total assets (up to 50% under normal market conditions) at the time of purchase in securities issued by companies that are economically
tied to emerging and frontier markets. Emerging and frontier markets are those countries currently excluded from the MSCI World Index
of developed markets.

Analytical Approach

The Adviser uses a process of quantitative
screening of the financial trends and health of each company in its investment universe, followed by “bottom up” fundamental
analysis to identify value-based investment opportunities. This fundamental analysis generally includes a study of the company’s
financial performance, its management, its competitors, its industry, its competitive advantage, its governance and policies, the geographic
region(s) to which it is economically tied, and talking with the management team. In performing such analysis, the Adviser seeks to evaluate
each company’s long-term potential. The Adviser also travels on an as-needed basis to visit companies and expects to speak directly
with senior management.

The Adviser incorporates the results
of this analysis into its overall decision-making but does not necessarily include or exclude a particular company solely based on the
Adviser’s assessment of any single criterion.

The Fund may also invest in
companies that do not fit into one of these three categories, but which the Adviser believes are trading at attractive valuations with
potential returns consistent with the objective of the Fund. The Fund may invest in early-stage companies and Initial Public Offerings
(IPOs).

The Adviser directs the Fund to invest
in what it believes to be the most attractive investments available without regard to benchmark weightings in regions, countries, or industries.
The Adviser may significantly shift Fund assets between asset classes, sectors and geographic regions based on where it believes the best
long-term opportunities and valuations currently exist. The Fund may invest a significant percentage of its assets in a few sectors (e.g.,
the financials sector or technology sector) or regions (e.g., Europe or Asia).

Deborah O’Neal, Esq.

May 23, 2025

Page 5

Comment 6: If the Fund is aware now to which
sector it is most likely to be exposed, please identify that sector in the principal investment strategy disclosures and add corresponding
principal investment risk disclosure.

Response: The Registrant refers to its response
to Comment 5.

The Registrant has further added “Financial
Sector Risk” to the Fund’s principal investment risk disclosures.

Comment 7: Consider expanding “Limited
History of Operations Risk” to include other risks associated with new funds.

Response: The Registrant has amended its disclosures
to the state the following:

Limited History of Operations
Risk. The Fund has only recently commenced operations and therefore has no a limited history of
operations for investors to evaluate. There can be no assurance that the Fund will grow to or maintain an economically viable
size.

Comment 8: Please identify supplementally which
broad-based market index the Fund intends to use as its primary benchmark.

Response: The Registrant has confirmed with
the adviser that the Fund intends to use the MSCI ACWI IMI ex-US Index as its primary benchmark.

Comment 9: The Fund’s Item 9 principal
investment strategy and risk disclosures are largely identical to that of its Item 4 principal investment strategy and risk disclosures.
Item 4 is intended to be a summary of the Fund’s Item 9 disclosures. Please consider revisions to the Fund’s disclosures consistent
with this layered approach.

Response: The Registrant refers to its response
to Comment 5.

Comment 10: In the Table of Risks in the Fund’s
Item 9 disclosure, please reconcile “Sector Concentration Risk” with the “Sector Exposure Risk” as used in the
Fund’s Item 4 disclosures.

Response: The Registrant has amended its disclosures
to reflect “Sector Exposure Risk” consistently throughout the registration statement.

Deborah O’Neal, Esq.

May 23, 2025

Page 6

If you have any questions, please call JoAnn M. Strasser
at (614) 469-3265 or the undersigned at (614) 469-3217.

Very truly yours,

/s/ Philip B. Sineneng

Philip B. Sineneng

 cc: JoAnn M. Strasser