SecProbe.io

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 Global Indemnity Group, LLC
 112 S. French Street, Suite 105
 Wilmington, Delaware 19801
 June 18, 2025 VIA EDGAR
 U.S. Securities and Exchange Commission Division of Corporation
Finance 100 F Street, NE Washington, DC 20549
 Attn: Madeleine Mateo

 Re:
 Global Indemnity Group, LLC

  
 Registration Statement on Form S-3

  
 File No. 333-287946
 Ladies and Gentlemen: Pursuant to Rule 461(a) under the
Securities Act of 1933, as amended, Global Indemnity Group, LLC, a Delaware limited liability company (the “Registrant”), respectfully requests that the effective date of the Registration Statement on Form
 S-3 (File No. 333-287946), filed by the Registrant on June 11, 2025, be accelerated by the Securities and Exchange Commission to 4:00 p.m. Eastern Time,
on June 23, 2025, or as soon thereafter as practicable. The Registrant respectfully requests that it be notified of such effectiveness by a
telephone call to Dwight S. Yoo of Skadden, Arps, Slate, Meagher & Flom LLP at (212) 735-2573 and that such effectiveness also be confirmed in writing.

 Very truly yours,

 GLOBAL INDEMNITY GROUP, LLC

 By:

 /s/ Brian J. Riley

 Name:

 Brian J. Riley

 Title:

 Chief Financial Officer

 cc:
 Dwight S. Yoo, Skadden, Arps, Slate, Meagher & Flom LLP
 [ Signature Page to S-3 Acceleration Request ]

<DOCUMENT>
<TYPE>TEXT-EXTRACT
<SEQUENCE>2
<FILENAME>filename2.txt
<TEXT>
 June 18, 2025

Brian J. Riley
Chief Financial Officer
Global Indemnity Group, LLC
112 S. French Street, Suite 105
Wilmington, DE 19801

 Re: Global Indemnity Group, LLC
 Registration Statement on Form S-3
 Filed June 11, 2025
 File No. 333-287946
Dear Brian J. Riley:

 This is to advise you that we have not reviewed and will not review your
registration
statement.

 Please refer to Rules 460 and 461 regarding requests for acceleration.
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 action
by the staff.

 Please contact Madeleine Joy Mateo at 202-551-3465 with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Finance
cc: Dwight S. Yoo, Esq.
</TEXT>
</DOCUMENT>

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 Global Indemnity Group, LLC

GBLI Holdings, LLC

 Three
Bala Plaza East, Suite 300

 Bala Cynwyd, Pennsylvania 19004

August 13, 2021

 VIA EDGAR

 Securities and Exchange Commission

 Division of
Corporation Finance

 100 F Street N.E.

 Washington, D.C.
20549

Re:
 Global Indemnity Group, LLC

GBLI Holdings, LLC

Request for Acceleration

Registration Statement on Form S-3

File No. 333-258317 (the “Registration Statement”)

 Ladies and Gentlemen:

 In accordance with
Rules 460 and 461 under the Securities Act of 1933, as amended (the “Securities Act”), Global Indemnity Group, LLC, a Delaware limited liability company (“Global Indemnity”), and GBLI Holdings, LLC, a Delaware
limited liability company (together with Global Indemnity, the “Companies”), respectfully request that the effective date of the above-referenced Registration Statement be accelerated by the Securities and Exchange Commission (the
“Commission”) so that the Registration Statement, as then amended, will become effective under the Securities Act at 4:00 p.m., New York City time, on Thursday, August 19, 2021 or at such later time as the Companies or their
counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Commission.

 The Companies
request that they be notified of such effectiveness by a telephone call to Dwight S. Yoo of Skadden, Arps, Slate, Meagher & Flom LLP, the Companies’ counsel, at (212) 735-2573, and that such
effectiveness also be confirmed in writing.

 [Signature Page Follows]

Very truly yours,

GLOBAL INDEMNITY GROUP, LLC

By:

 /s/ Thomas M. McGeehan

Name:

Thomas M. McGeehan

Title:

Chief Financial Officer

GBLI HOLDINGS, LLC

By:

 /s/ Thomas M. McGeehan

Name:

Thomas M. McGeehan

Title:

Chief Financial Officer

cc:
 Dwight S. Yoo

Skadden, Arps, Slate, Meagher & Flom LLP

Stephen W. Ries

 Global Indemnity
Group, LLC

 [Signature Page to
Acceleration Request]

United States securities and exchange commission logo
August 9, 2021
Thomas M. McGeehan
Chief Financial Officer
Global Indemnity Group, LLC
Three Bala Plaza East, Suite 300
Bala Cynwyd, PA 19004
Re:Global Indemnity Group, LLC
Registration Statement on Form S-3
Filed July 30, 2021
File No. 333-258317
Dear Mr. McGeehan:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 action by the staff.
            Please contact Sonia Bednarowski at 202-551-3666 or Justin Dobbie, Legal Branch
Chief, at 202-551-3469 with any questions.
Sincerely,
Division of Corporation Finance
Office of Finance

United States securities and exchange commission logo
July 17, 2020
Thomas M. McGeehan
Chief Financial Officer
Global Indemnity Limited
27 Hospital Road
George Town, Grand Cayman
KY1-9008, Cayman Islands
Re:Global Indemnity Limited
Preliminary Proxy Statement on Schedule 14A
Filed June 23, 2020
File No. 001-34809
Dear Mr. McGeehan:
            We have completed our review of your filing.  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 action by the staff.
Sincerely,
Division of Corporation Finance
Office of Finance

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 GLOBAL INDEMNITY LIMITED

27 Hospital Road

 George Town,
Grand Cayman

 KY1-9008, Cayman Islands

July 16, 2020

 VIA EDGAR

Mr. Dieter King

 U.S.
Securities and Exchange Commission

 Division of Corporation Finance

Office of Finance

 100 F. Street N.E.

Washington, D.C. 20549

RE:
 Global Indemnity Limited

Amendment No. 1 to Proxy Statement on Form PRER 14A

Filed July 15, 2020 (File No. 001-34809)

 Dear Mr. King:

As discussed with the staff of the Division of Corporation Finance (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) on July 16, 2020, Global Indemnity Limited (the “Company,” “we,” “us,” or “our”) is
hereby filing via EDGAR Amendment No. 2 (“Amendment No. 2”) to the preliminary proxy statement on Form PRE 14A, File No. 001-34809, originally
filed with the Commission on June 23, 2020 (the “Proxy Statement”). Amendment No. 2 reflects the certain updated, revised and supplemental information, as discussed on July 16, 2020. Marked copies of Amendment
No. 2 showing changes from the Proxy Statement will be delivered to your attention as well.

 Should you or any member
of the Staff have any questions, or need additional information, please do not hesitate to contact David C. Eisman, the Company’s legal advisor, at (213) 687-5010.

 Very truly yours,

 GLOBAL INDEMNITY LIMITED

 By:

 /s/ Thomas M. McGeehan

 Name:

 Thomas M. McGeehan

 Title:

 Chief Financial Officer

 Enclosures

 cc: David C.
Eisman, Skadden, Arps, Slate, Meagher & Flom LLP

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 GLOBAL INDEMNITY LIMITED

27 Hospital Road

 George Town,
Grand Cayman

 KY1-9008, Cayman Islands

July 15, 2020

 VIA EDGAR

Mr. Dieter King

 U.S. Securities and Exchange Commission

 Division of Corporation Finance

 Office of Finance

100 F. Street N.E.

 Washington, D.C. 20549

RE:
 Global Indemnity Limited Proxy Statement on Form PRE 14A

Filed June 23, 2020 (File No. 001-34809)

Dear Mr. King:

 As discussed with the staff
of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) on July 9, 2020, Global Indemnity Limited (the “Company,”
“we,” “us,” or “our”) is hereby filing via EDGAR Amendment No. 1 (“Amendment No. 1”) to the preliminary proxy
statement on Form PRE 14A, File No. 001-34809, filed with the Commission on June 23, 2020 (the “Proxy Statement”). Amendment No. 1 reflects the certain updated, revised
and supplemental information, as discussed on July 9, 2020. Marked copies of Amendment No. 1 showing changes from the Proxy Statement will be delivered to your attention as well.

Should you or any member of the Staff have any questions, or need additional information, please do not hesitate to contact David C. Eisman,
the Company’s legal advisor, at (213) 687-5010.

Very truly yours,

GLOBAL INDEMNITY LIMITED

By:

 /s/ Thomas M. McGeehan

Name:

Thomas M. McGeehan

Title:

Chief Financial Officer

 Enclosures

 cc: David C.
Eisman, Skadden, Arps, Slate, Meagher & Flom LLP

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 August 16, 2018

VIA EDGAR

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-3720

Attention:
 Ada D. Sarmento

Erin Jaskot

Re:
 Global Indemnity Limited

 Global Indemnity Group, Inc.

 Registration Statement on Form S-3

 File No. 333-225758

Acceleration Request

Requested Date:            August 20, 2018

Requested Time:           4:00 P.M. Eastern Time

Ladies and Gentlemen:

 Pursuant to
Rule 461 under the Securities Act of 1933, as amended, Global Indemnity Limited and its wholly owned subsidiary Global Indemnity Group, Inc. (together, the “Company”) hereby request that the above-referenced Registration
Statement on Form S-3 (File No. 333-225758) (the “Registration Statement”) be declared effective at the “Requested Date” and
“Requested Time” set forth above or at such later time as the Company or its counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration
Statement has been declared effective, please orally confirm that event with our counsel, Wilson Sonsini Goodrich & Rosati, P.C., by calling Megan J. Baier at (212) 497-7736.

* * * *

Sincerely,

GLOBAL INDEMNITY LIMITED

By:

/s/ Thomas M. McGeehan

Thomas M. McGeehan

Chief Financial Officer

GLOBAL INDEMNITY GROUP, INC.

By:

/s/ Thomas M. McGeehan

Thomas M. McGeehan

Chief Financial Officer

cc:
 Stephen Ries, Esq

 Global Indemnity Limited

 Katharine A. Martin

 Megan J. Baier

 Wilson Sonsini Goodrich & Rosati, P.C.

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 August 14, 2018

Via Email, EDGAR and Courier

 Securities
and Exchange Commission

 Division of Corporation Finance

 100
F Street, N.E.

 Washington, D.C. 20549-3720

Attention:
 Ada D. Sarmento

 Erin Jaskot

           Re:
 Global Indemnity Limited

 Amendment No. 1 to Registration Statement on Form S-3

 Filed August 1, 2018

 File No. 333-225758

Ladies and Gentlemen:

 On behalf of our client,
Global Indemnity Limited (the “Company”), we are responding to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated
August 8, 2018 (the “Comment Letter”), relating to the above referenced Amendment No. 1 to Registration Statement on Form S-3 (“Amendment
No. 1”). The Company is concurrently filing via EDGAR this letter and Amendment No. 2 to the Registration Statement (“Amendment No. 2”). For the Staff’s reference, we are
providing to the Staff by courier both a clean copy of Amendment No. 2 and a copy marked to show all changes from Amendment No. 1 filed on August 1, 2018.

In this letter, we have recited the comment from the Staff in italicized, bold type and have followed the comment with the Company’s
response. Except for page references appearing in the headings and Staff comments below (which are references to Amendment No.1 submitted on August 1, 2018) all page references herein correspond to the page of Amendment No. 2.

 Securities and Exchange Commission

August 14, 2018

  Page
 2

 Amendment No. 1 to Form S-3 filed August 1, 2018

 Description of the Debt Securities, page 16

1.
 We note your disclosure on pages 16 and 27 that the debt securities that may be issued by the
Company and GIGI, as co-obligors, may be convertible. Please explain how this meets the requirements in Instruction I.C.4 of Form S-3 that the securities being
registered are non-convertible securities.

 The Company
acknowledges the Staff’s comments and respectfully advises the Staff that it has revised the disclosures on pages 16, 18, 23 and 27 of Amendment No. 2, and will be filing a revised Form of Indenture as Exhibit 4.2, to clarify that the debt
securities that may be issued by the Company and GIGI, as co-obligors, will not be convertible.

 Securities and Exchange Commission

August 14, 2018

  Page
 3

 Please direct any questions with respect to the Company’s responses to me at Megan J.
Baier, at (212) 497-7736 or mbaier@wsgr.com or my colleague Katharine A. Martin at (650) 565-3522 or kmartin@wsgr.com.

Sincerely,

WILSON SONSINI GOODRICH & ROSATI

Professional Corporation

/s/ Megan J. Baier

Megan J. Baier

 Enclosures

cc (w/enclosures):
  Thomas M. McGeehan

  Stephen Ries, Esq

  Global Indemnity Limited

  Katharine A. Martin

  Wilson Sonsini Goodrich & Rosati, P.C.

August 8, 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
Amendment No. 1 to Registration Statement on Form S-3
Filed August 1, 2018
File No. 333-225758
Dear Ms. Valko:
            We have reviewed your amended registration statement and have the following
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.
Amendment No. 1 to Form S-3 filed August 1, 2018
Description of the Debt Securities, page 16
1.We note your disclosure on pages 16 and 27 that the debt securities that may be issued by
the Company and GIGI, as co-obligors, may be convertible.  Please explain how this
meets the requirement in Instruction I.C.4 of Form S-3 that the securities being registered
are non-convertible securities.

 FirstName LastNameCynthia Y. Valko
 Comapany NameGlobal Indemnity Limited
 August 8, 2018 Page 2
 FirstName LastName
Cynthia Y. Valko
Global Indemnity Limited
August 8, 2018
Page 2
            Please contact Ada D. Sarmento at 202-551-3798 or Erin Jaskot at 202-551-3442 with
any questions.
Sincerely,
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Megan J. Baier, Esq.

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 August 1, 2018

Via Email, EDGAR and Courier

 Securities
and Exchange Commission

 Division of Corporation Finance

 100
F Street, N.E.

 Washington, D.C. 20549-3720

Attention:
Ada D. Sarmento

Erin Jaskot

Re:
Global Indemnity Limited

Registration Statement on Form S-3

Filed June 20, 2018

File No. 333-225758

 Ladies and Gentlemen:

On behalf of our client, Global Indemnity Limited (the “Company”), we are responding to the comments of the staff (the
“Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated July 3, 2018 (the “Comment Letter”), relating to the above referenced Registration Statement
on Form S-3 (the “Registration Statement”). The Company is concurrently filing via EDGAR this letter and Amendment No. 1 to the Registration Statement (“Amendment
No. 1”). For the Staff’s reference, we are providing to the Staff by courier both a clean copy of the Registration Statement and a copy marked to show all changes from Registration Statement filed on June 20,
2018.

 In this letter, we have recited the comment from the Staff in italicized, bold type and have followed the comment with the
Company’s response. Except for page references appearing in the headings and Staff comments below (which are references to the original Registration Statement submitted on June 20, 2018) all page references herein correspond to the page of
Amendment No. 1.

 Securities and Exchange Commission

August 1, 2018

  Page
 2

 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.

The Company acknowledges the Staff’s comment and respectfully advises the Staff that Global Indemnity Group, Inc. (the “Registrant-Sub”) is eligible to register this offering on Form S-3 by relying upon Instruction I.C to Form S-3.

General Instruction I. of Form S-3 states that majority-owned subsidiaries must comply with General
Instruction I.C. of Form S-3. General Instruction I.C. of Form S-3 sets forth five conditions, any one of which must be satisfied. The language of General
Instruction I.C.4. of Form S-3, Global Indemnity Limited, can be broken up into three distinct requirements: (A) the parent of the registrant-subsidiary meets the Registrant Requirements, (B) the
parent of the registrant-subsidiary meets the applicable Transaction Requirement, and (C) the securities of the registrant subsidiary being registered are full and unconditional guarantees, as defined in
Rule 3-10 of Regulation S-X, of the payment obligations on the parent’s non-convertible securities, other than
common equity, being registered.

 (A) The Parent of the registrant-subsidiary meets the applicable Registrant Requirements.

The Company, as the parent of Registrant-Sub, meets the Registration Requirement of
Form S-3 in accordance with the applicable numbered subsections corresponding to the General Instruction I.A.:

(2) Global Indemnity Limited has registered its A Ordinary Shares pursuant to Section 12(b) of the Securities Exchange Act
of 1934, as amended (the “Exchange Act”);

 (3) Global Indemnity Limited (a) has been subject to the
requirements of Section 12 of the Exchange Act and has filed all the material required to be filed pursuant to Sections 13, 14 or 15(d) of the Exchange Act for at least twelve calendar months immediately preceding the filing of the Registration
Statement, and (b) has filed in a timely manner all reports (except as noted in General Instruction I.A. of Form S-3) required to be filed during the twelve calendar months and any portion of the month
immediately preceding the filing of the Registration Statement. Furthermore, Global Indemnity Limited has not used Rule 12b-25(b) under the Exchange Act during the twelve calendar months and any portion of the
month immediately preceding the filing of the Registration Statement;

 Securities and Exchange Commission

August 1, 2018

  Page
 3

 (4) Neither Global Indemnity Limited nor any of its subsidiaries have since
the end of the last fiscal year for which certified financial statements of Global Indemnity Limited and its consolidated subsidiaries were included in a report filed pursuant to Section 13(a) or 15(d) of the Exchange Act: (a) failed to
pay any dividend or sinking fund installment on preferred stock; or (b) defaulted (i) on any installment or installments on indebtedness for borrowed money, or (ii) on any rental on one or more long term leases;

(5) Global Indemnity Limited, a Cayman Islands exempted company, is a foreign issuer which satisfies all of the enumerated
registrant eligibility requirements except the provisions in I.A.l. relating to organization and principal business and files the same reports with the Commission under Section 13(a) or 15(d) of the Exchange Act as a domestic registrant
pursuant to I.A.3.

 (6) Global Indemnity Limited is deemed to be a successor registrant and therefore is deemed to have met
conditions 2., 3., and 5., above since: (a) its predecessor, Global Indemnity, plc, and it, taken together, have met the conditions in 2., 3. and 5. above and because the succession was primarily for the purpose of changing the jurisdiction of
incorporation from Ireland to the Cayman Islands and the assets and liabilities of the Global Indemnity Limited at the time of succession were substantially the same as those of Global Indemnity, plc; and (b) Global Indemnity plc met the
conditions at the time of succession and Global Indemnity, Limited, as the registrant, has continued to do so since the succession.

(7) Global Indemnity Limited has filed with the Commission (1) all required electronic filings and (2) all Financial
Data Schedules required to be submitted pursuant to Item 601(c) of Regulation S-K.

 (B) The
parent of the registrant-subsidiary meets the applicable Transaction Requirement.

 The Company, as the parent of Registrant-Sub, meets the Transaction Requirement of Form S-3 in accordance with General Instruction B.1. of Form S-3, which sets
forth three additional conditions, any one of which must be satisfied. Subsection A states that the registrant must meet the aggregate market value requirement of General Instruction I.B.1. of Form S-3, which
states that the aggregate market value of the voting and non-voting common equity held by non-affiliates of Global Indemnity Limited must be $75 million or more. As
of May 2, 2018, 10,075,346 shares of Global Indemnity Limited’s A Ordinary Shares were outstanding and 8,326,840 of those shares were held by non-affiliates. With a closing sales price on
June 26, 2018 of $41.65 per share, the aggregate market value of the voting and non-voting common equity held by non-affiliates was approximately $347 million.

 Securities and Exchange Commission

August 1, 2018

  Page
 4

 (C) The securities of the registrant-subsidiary being registered are full and
unconditional guarantees, as defined in Rule 3-10 of Regulation S-X, of the payment obligations on the parent’s
non-convertible securities, other than common equity, being registered.

 The
Company and the Registrant-Sub will only issue debt securities as co-obligors, with the debt securities being unsecured obligations of the Company and the
Registrant-Subs, on a joint and several basis, as described on page [16] of Amendment No. 1. The Company believes that the legal remedy for an investor in such debt securities for non-payment is
equivalent if the Company and the Registrant-Sub are co-obligors or if one party has provided a full and unconditional guarantee insofar as such investor may hold either
entity liable for the non-payment. As such, the Company believes this structure is consistent with the intent of this requirement Instruction I.C.4. of Form S-3.
Further, Note 1 to Rule 3-10(c) of Regulation S-X expressly provides that the exception set forth in Rule 3-10(c) of Regulation S-X is available for debt securities co-issued by the parent and its operating subsidiary.

Furthermore, as previously disclosed on Form 8-K, filed on May 1, 2018, on
April 25, 2018, the Company and Registrant-Sub, entered into a Third Supplemental Indenture (the “Third Supplemental Indenture”) to the Indenture, dated as of August 12, 2015 (the
“Base Indenture”), by and between the Company (as successor to Global Indemnity plc), and Wells Fargo Bank, National Association (the “7.75% Notes Trustee”), as trustee with respect to the 7.75% Subordinated Notes
due 2045 of the Company (the “7.75% Notes”), as supplemented by a supplemental indenture, dated November 7, 2016 (the “First Supplemental Indenture”), between the Company, Global Indemnity plc and the 7.75% Notes
Trustee, and as further supplemented with respect to the Notes by a Second Supplemental Indenture, dated as of March 23, 2017 (the “Second Supplemental Indenture” and, together with the Base Indenture and the First Supplemental
Indenture, the “Indenture”), by and among the Company, the 7.75% Notes Trustee and U.S. Bank National Association, as trustee with respect to the 7.875% Subordinated Notes due 2047 of the Company (the “7.875%
Notes”, and together with the 7.75% Notes, the “Notes”). Pursuant to the Third Supplemental Indenture, the Registrant-Sub agreed to become a subordinated co-obligor with respect to each series of Notes with the same obligations and duties as the Company under the Indenture (including the due and punctual performance and observance of all of the covenants and
conditions to be performed by the Company, including, without limitation, the obligation to pay the principal of and interest on the Notes of any series when due whether at maturity, by acceleration, redemption or otherwise), and with the same
rights, benefits and privileges of the Company thereunder.

 Securities and Exchange Commission

August 1, 2018

  Page
 5

 Due to the Registrant-Sub’s
entry into the Third Supplemental Indenture in the Company’s second quarter, the Company will include condensed consolidating financial information for the Registrant-Sub in a footnote to the
Company’s financial statements starting with its Form 10-Q for the quarter ended June 30, 2018 in compliance with Rule 3-10(c) of Regulation S-X.

 The Company respectfully advises the Staff that it has updated the disclosure in
Amendment No. 1 so that the Registrant-Sub is only registering debt securities and not warrants, which will only be registered by the Company.

For the reasons stated above, the Company believes that Global Indemnity Group, Inc. is eligible to register this offering on Form S-3 pursuant to Instruction I.C of Form S-3.

 Securities and Exchange Commission

August 1, 2018

  Page
 6

 Please direct any questions with respect to the Company’s responses to
me at Megan J. Baier, at (212) 497-7736 or mbaier@wsgr.com or my colleague Katharine A. Martin at (650) 565-3522 or kmartin@wsgr.com.

Sincerely,

 WILSON SONSINI GOODRICH &

 ROSATI
Professional Corporation

 /s/ Megan J. Baier

 Megan J. Baier

 Enclosures

cc (w/ enclosures):

Thomas M. McGeehan

Stephen Ries, Esq

Global Indemnity Limited

Katharine A. Martin

Wilson Sonsini Goodrich & Rosati, P.C.

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.

CORRESP
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SEC Correspondence

 July 2, 2018

VIA EDGAR

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-3720

Attention:    Ada Sarmento

Re:
Global Indemnity Limited

Registration Statement on Form S-3

File No. 333-225695

Acceleration Request

        Requested Date:        July 5, 2018

        Requested Time:       4:00 P.M. Eastern Time

Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, Global Indemnity Limited (the “Company”) hereby requests that the above-referenced Registration Statement on Form S-3 (File No. 333-225695) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or at such later time as the Company or its
counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our
counsel, Wilson Sonsini Goodrich & Rosati, P.C., by calling Megan J. Baier at (212) 497-7736.

* * * *

 Sincerely,

GLOBAL INDEMNITY LIMITED

By:

/s/ Thomas M. McGeehan

 Thomas M. McGeehan

 Chief Financial
Officer

cc:
Stephen W. Ries, Esq.

 Global Indemnity Limited

Katharine A. Martin

 Megan J.
Baier

 Wilson Sonsini Goodrich & Rosati, P.C.

June 29, 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 18, 2018
File No. 333-225695
Dear Ms. Valko:
            This is to advise you that we have not reviewed and will not review your registration
statement.
            Please refer to Rules 460 and 461 regarding requests for acceleration.  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 action by the staff.
            Please contact Ada D. Sarmento at 202-551-3798 with any questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc:       Megan J. Baier, Esq.

CORRESP
1
filename1.htm

CORRESP

 April 30, 2018

VIA EDGAR

 Securities and Exchange Commission

Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-3720

Attention:
Christine Westbrook

 Erin Jaskot

Re:
Global Indemnity Limited

 Registration Statement on Form S-3

 File No. 333-223546

Acceleration Request

Requested Date: May 2, 2018

Requested Time: 4:00 P.M. Eastern Time

Ladies and Gentlemen:

 Pursuant to Rule 461
under the Securities Act of 1933, as amended, Global Indemnity Limited (the “Company”) hereby requests that the above-referenced Registration Statement on Form S-3 (File No. 333-223546) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or at such later time as the Company or its
counsel may orally request via telephone call to the staff of the Division of Corporation Finance of the Securities and Exchange Commission. Once the Registration Statement has been declared effective, please orally confirm that event with our
counsel, Wilson Sonsini Goodrich & Rosati, P.C., by calling Megan J. Baier at (212) 497-7736.

* * * *

Sincerely,

GLOBAL INDEMNITY LIMITED

By:

 /s/ Thomas M. McGeehan

Thomas M. McGeehan

Chief Financial Officer

cc:
Stephen Ries, Esq

 Global Indemnity Limited

Katharine A. Martin

 Megan
J. Baier

 Wilson Sonsini Goodrich & Rosati, P.C.

CORRESP
1
filename1.htm

CORRESP - SEC Response Letter

 April 30, 2018

Via Email, EDGAR and Courier

 Securities
and Exchange Commission

 Division of Corporation Finance

 100
F Street, N.E.

 Washington, D.C. 20549-3720

Attention:

Christine Westbrook

Erin Jaskot

Re:
Global Indemnity Limited

 Registration Statement on Form S-3

 Filed March 9, 2018

File No. 333-223546

Ladies and Gentlemen:

 On behalf of our client,
Global Indemnity Limited (the “Company”), we are responding to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in its letter dated
March 19, 2018 (the “Comment Letter”), relating to the above referenced Registration Statement on Form S-3 (the “Registration Statement”). The Company is concurrently
filing via EDGAR this letter and Amendment No. 1 to the Registration Statement (“Amendment No. 1”). For the Staff’s reference, we are providing to the Staff by courier both a clean copy of the
Registration Statement and a copy marked to show all changes from Registration Statement filed on March 9, 2018.

 In this letter, we
have recited the comments from the Staff in italicized, bold type and have followed each comment with the Company’s response. Except for page references appearing in the headings and Staff comments below (which are references to the original
Registration Statement submitted on March 9, 2018) all page references herein correspond to the page of Amendment No. 1, as applicable.

Incorporation by Reference, page 9

 Securities and Exchange Commission

April 30, 2018

 Page 2

1.
Item 12(a)(2) of Form S-3 requires that specified documents be incorporated by reference by means of a statement to that effect in the prospectus listing all such
documents. Please revise your disclosure to list the reports filed pursuant to Section 13(a) or 15(d) of the Exchange Act since the end of the fiscal year covered by the annual report incorporated by
reference under Item 12(a)(1) of Form S-3.

 The Company acknowledges
the Staff’s comment and respectfully advises the Staff that it has revised the disclosure on page 9 to list the reports filed pursuant to Section 13(a) or 15(d) of the Exchange Act since the end of the fiscal year covered by the annual
report incorporated by reference under Item 12(a)(1) of Form S-3.

2.
We note that your registration statement incorporates by reference your Form 10-K for the fiscal year ended
December 31, 2017, which in turn incorporates by reference Part III information from a proxy statement that you have not yet filed. Please be advised that we will not be in a position to accelerate the
effective date of your registration statement until you have amended your Form 10-K to include Part III information or filed the definitive proxy statement. Please refer to Securities Act Forms Compliance and
Disclosure Interpretations Question 123.01 for guidance.

 The Company acknowledges the Staff’s comment
and respectfully advises the Staff that it has filed its Definitive Proxy Statement on Schedule 14A with the Commission on April 30, 2018. The Company has revised the disclosure on page 9 accordingly.

 Securities and Exchange Commission

April 30, 2018

 Page 3

 Please direct any questions with respect to the Company’s responses
or Amendment No. 1 to me at (650) 565-3522 or kmartin@wsgr.com, or to my colleague, Megan J. Baier, at (212) 497-7736 or mbaier@wsgr.com.

Sincerely,

WILSON SONSINI GOODRICH & ROSATI, Professional Corporation

 /s/ Katharine A. Martin

 Katharine A.
Martin

 Enclosures

cc (w/ enclosures):

Thomas M. McGeehan

Stephen Ries, Esq

Global Indemnity Limited

Megan J. Baier

Wilson Sonsini Goodrich & Rosati, P.C.

March 19, 2018
Thomas M.  McGeehan
Chief Financial 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 March 9, 2018
File No. 333-223546
Dear Mr. McGeehan:
            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.
Form S-3 filed on March 9, 2018
Incorporation by Reference, page 9
1.Item 12(a)(2) of Form S-3 requires that specified documents be incorporated by reference
by means of a statement to that effect in the prospectus listing all such documents. Please
revise your disclosure to list the reports filed pursuant to Section 13(a) or 15(d) of the
Exchange Act since the end of the fiscal year covered by the annual report incorporated by
reference under Item 12(a)(1) of Form S-3.

 FirstName LastNameThomas M.  McGeehan
 Comapany NameGlobal Indemnity Limited
 June 16, 2017 Page 2
 FirstName LastName
Thomas M.  McGeehan
Global Indemnity Limited
March 19, 2018
Page 2
General
2.We note that your registration statement incorporates by reference your Form 10-K for the
fiscal year ended December 31, 2017, which in turn incorporates by reference Part III
information from a proxy statement that you have not yet filed. Please be advised that we
will not be in a position to accelerate the effective date of your registration statement until
you have amended your Form 10-K to include Part III information or filed the definitive
proxy statement. Please refer to Securities Act Forms Compliance and Disclosure
Interpretations Question 123.01 for guidance.
            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
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 Christine Westbrook at (202) 551-5019 or Erin Jaskot at (202) 551-
3442 with any other questions.
Division of Corporation Finance
Office of Healthcare & Insurance
cc: Stephen Ries, Esq.

July 13, 2015

Via E -mail
Thomas M. McGeehan
Chief Financial Officer
c/o Global Indemnity Group, Inc.
Three Bala Plaza East, Suite 300
Bala Cynwyd, P ennsylvania  19004

Re: Global Indemnity plc
Registration Statement on Form S-3
Filed  July 2 , 2015
  File No.  333-205451

Dear Mr. McGeehan :

This is to advise you that we have not  reviewed and will not review your registration
statement .

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   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 the event you request acceleration of t he effective date of the pending regist ration
statement please provide  a written statement from the company acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not foreclose  the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the ade quacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the Unite d States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting acceleration are aw are of their respective responsibilities under

Thomas M. McGeehan
Global Indemnity Group, Inc.
July 1 3, 2015
Page 2

 the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the registered securities .

You may contact Tara Keating Brooks  at (202) 551 -8336  or me at  (202) 551 -3715 with
any questions.

Sincerely,

 /s/ Jeffrey P. Riedler

 Jeffrey P. Riedler
Assistant Director

cc: Via E -mail
Jonathan Ko
Skadden, Arps, Slate, Meagher & Flom LLP

CORRESP
1
filename1.htm

Acceleration Request

 Global Indemnity plc

c/o Global Indemnity Group, Inc.

Three Bala Plaza East, Suite 300

Bala Cynwyd, Pennsylvania 19004

(610) 664-1500

July 13, 2015

 VIA EDGAR

Mr. Jeffrey P. Riedler

 Assistant Director

Division of Corporation Finance

 Securities and Exchange
Commission

 100 F Street, N.E.

 Washington, D.C. 20549

                        Re:

Acceleration Request

Global Indemnity plc

Registration Statement on Form S-3

(File No. 333-205451)

 Dear Mr. Riedler:

Pursuant to Rule 461(a) under the Securities Act of 1933, as amended, Global Indemnity plc (the “Company”) hereby requests
that the effectiveness of the Registration Statement on Form S-3 (Registration No. 333-205451) (the “Registration Statement”) be accelerated so that it will become effective no later than 9:00 a.m., Washington, D.C. time, on
Wednesday, July 15, 2015, or as soon thereafter as practicable.

 The Company confirms that:

(i)
should the Securities and Exchange Commission (the “Commission”) or its staff, acting pursuant to delegated authority, declare the Registration Statement effective, such action does not foreclose the
Commission from taking any action with respect to the Registration Statement;

(ii)
the action of the Commission or its staff, acting pursuant to delegated authority, in declaring the Registration Statement effective does not relieve the Company from its full responsibility for the adequacy and
accuracy of the disclosure in the Registration Statement; and

(iii)
the Company may not assert staff comments and the declaration of effectiveness of the Registration Statement as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of
the United States.

 We request that we be notified of such effectiveness by a telephone call to Jonathan Ko of Skadden,
Arps, Slate, Meagher & Flom LLP at (213) 687-5527 and that such effectiveness also be confirmed in writing.

 Please contact
the undersigned at (610) 664-1500 if there are any questions regarding this matter.

 [Signature Page Follows]

 Sincerely,

GLOBAL INDEMNITY PLC

By:

/s/ Thomas M. McGeehan

 Name: Thomas M. McGeehan

 Title:
  Chief Financial Officer

cc:

Tara Keating Brooks — Securities and Exchange Commission

Amr Razzak — Skadden, Arps, Slate, Meagher & Flom LLP

Gregg Noel — Skadden, Arps, Slate, Meagher & Flom LLP

Jonathan Ko — Skadden, Arps, Slate, Meagher & Flom LLP

 [Signature Page to Acceleration Request Letter (Form S-3)]

CORRESP
1
filename1.htm

Acceleration Request

 Thomas M. McGeehan

Executive Vice President

Chief Financial Officer

 May 1, 2015

VIA EDGAR

 Securities and Exchange Commission

 Division of Corporation Finance

 100 F Street, N.E.

Washington, D.C. 20549-3720

Attention:

Jeffrey P. Riedler

Johnny Gharib

Re:

Global Indemnity plc

Registration Statement on Form S-3

File No. 333-202804

Acceleration Request

Requested Date:

May 5, 2015

Requested Time:

4:00 P.M. Eastern Time

 Ladies and Gentlemen:

Pursuant to Rule 461 under the Securities Act of 1933, as amended, Global Indemnity plc (the “Company”) hereby requests
that the above-referenced Registration Statement on Form S-3 (File No. 333-202804) (the “Registration Statement”) be declared effective at the “Requested Date” and “Requested Time” set forth above or at such
later time as the Company or its counsel may orally request via telephone call to the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission”).

In connection with the acceleration request, the Company hereby acknowledges that:

•

should the Commission or the Staff, acting pursuant to delegated authority, declare the Registration Statement effective, it does not foreclose the Commission from taking any action with respect to the Registration
Statement;

•

the action of the Commission or the Staff, acting pursuant to delegated authority, in declaring the Registration Statement effective, does not relieve the Company from its full responsibility for the adequacy and
accuracy of the disclosure in the Registration Statement; and

•

the Company may not assert Staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

 Securities and Exchange Commission

May 1, 2015

  Page
 2

 Please provide a copy of the Commission’s order declaring the registration statement
effective to Katherine A. Martin, Esq. and Lisa L. Stimmell, Esq. via facsimile at (650) 493-6811 and via mail at Wilson Sonsini Goodrich & Rosati, Professional Corporation, 650 Page Mill Road, Palo Alto, California 94304-1050.

[Signature page follows]

* * * *

Sincerely,

Global Indemnity

/s/ Thomas M. McGeehan

Thomas M. McGeehan

Chief Financial Officer

cc:

Katharine A. Martin

Wilson Sonsini Goodrich & Rosati, P.C.

March 30, 2015

Via E -mail
Thomas M. McGeehan
Chief Financial Officer
Global Indemnity plc
25/28 North Wall Quay
Dublin 1
Ireland

Re: Global Indemnity plc
  Registration Statement on Form S -3
Filed  March 16 , 2015
  File No.  333-202804

Dear Mr. McGeehan :

We have limited our review of you r registration statement to the issue  we have addressed
in our comment .

Please respond to this letter by amending your registration statement and providing the
requested information .  Where  you do not believe our comment applies  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 sta tement and the information you
provide in response to our comment , we may have  additional comments.

General

1. We note that you have incorporated by reference your Form 10 -K for the fiscal year
ended December 31, 2014 and that your Form 10 -K incorporates Part III information by
reference to your definitive proxy statement that has not yet been filed.   Please be advised
that we cannot accelerate the effective date of your registration statement until you file
the information required by Part III of Form 10 -K.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Act of 193 3 and
all applicable Securities  Act rules require.   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.

Thomas M. McGeehan
Global Indemnity plc
March 30 , 2015
Page 2

 Notwithstanding our comment , in the event you request accelerat ion of the effective date
of the pending registration statement please provide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting pursuant to delegated authority, declare the
filing effective, it does not f oreclose the Commission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments and the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal
securities laws of the United States.

Please refer to Rules 460 and 461 regarding requests for  acceleration .  We will consider a
written request for acceleration of the effective date of the registration statement as confirmation
of the fact that those requesting accelerati on are aware of their respective responsibilities under
the Securities Act of 1933 and the Securities Exchange Act of 1934 as they relate to the proposed
public offering of the securities specified in the above registration statement.  Please allow
adequat e time  for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Johnny Gharib at (202) 551 -3170 or me at (202) 551 -3715  with any
questions.

Sincerely,

 /s/ Bryan J. P itko for

 Jeffrey P. Riedler
Assistant Dire ctor

January  22, 2015

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 14, 2014
File No. 001 -34809

Dear Mr. McGeehan:

We have completed our review of your filing .  We remind you that our comment s or
changes to disclo sure in response to our comment s do not foreclose the Commission from taking
any action with respe ct to the company or 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.   We u rge 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 in the Securities Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Joel Parker

Joel Parker
Accounting Branch Chief

CORRESP
1
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SEC Response Letter

 January 20, 2015

VIA EDGAR

 Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

 Division of Corporation
Finance

 United States Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

RE:
Global Indemnity plc

 Form 10-K for the Fiscal Year Ended December 31, 2013

Filed March 14, 2014

 File
No. 001-34809

 Dear Mr. Rosenberg:

 On behalf of
Global Indemnity plc (the “Company”), I am providing the following responses to the comments made in the Staff’s letter dated December 23, 2014 regarding the Company’s Annual Report on Form 10-K (“Form 10-K”) for
the fiscal year ended December 31, 2013, filed on March 14, 2014. To assist in your review, the text of the comment is repeated below with the Company’s response immediately following.

Report of Independent Registered Public Accounting Firm, page 89

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

 In response to the
Staff’s comment, prospectively, the Company will ensure that the name of the Company’s auditor, PricewaterhouseCoopers LLP, is included on the Report of Independent Registered Public Accounting Firm in the Company’s Form 10-K.

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. insurance subsidiaries, include the disclosure required by ASC 944-505-50-1b.

Provide similar information for Wind River Reinsurance, as applicable.

In response to the Staff’s comment, the Company reviewed the disclosure required by ASC 944-505-50-1b. For your information, both the U.S.
insurance subsidiaries’ and Global Indemnity

 Three Bala Plaza
East  |  Suite 300  |  Bala Cynwyd, PA 19004  |  P: 610.664.1500  |  F: 610.660.8882  |  www.globalindemnity.ie

 January 20, 2015

 Page

 Two

Reinsurance’s1 statutory capital and surplus significantly exceeded the minimum statutory capital and surplus necessary to satisfy
regulatory requirements. As of December 31, 2013, the Company’s total adjusted capital exceeded the “Company Action Level”, as described on page 142 of the Company’s Form 10-K, on a weighted average basis by 227% for its
U.S. insurance subsidiaries. As of December 31, 2013, Global Indemnity Reinsurance is required to meet a minimum solvency margin which they exceeded by approximately 19 times the minimum requirement. As such, additional disclosure under ASC
944-505-50-1b is not 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.

 The Company acknowledges that disclosing the amount of retained earnings or net income that is
restricted or free of restrictions for payment of dividends by Global Indemnity plc is appropriate according to Rule 4-08(e)(1) of Regulation S-X. The Company believes that this disclosure would be more
appropriate in the Company’s Shareholders’ Equity note.

 In response to the Staff’s comment, prospectively, the Company will
add the following disclosure to its Shareholders’ Equity note to the consolidated financial statements in the Company’s Form 10-K:

The ability of Global Indemnity plc to pay dividends is subject to Irish regulations. Under Irish law, dividends and distributions may only be
made from distributable reserves. As of December 31, 2013, the Company’s distributable reserves were $931.5 million.

 Since the
Company is a holding company and has no direct operations, its ability to pay dividends depends, in part, on the ability of its subsidiaries to pay dividends. Global Indemnity Reinsurance and the U.S. insurance subsidiaries are subject to
significant regulatory restrictions limiting their ability to declare and pay dividends. See note 20 for additional information regarding dividend limitations imposed on Global Indemnity Reinsurance and the U.S. insurance subsidiaries.

1
Wind River Reinsurance Company changed its name to Global Indemnity Reinsurance Company, Ltd. effective June 10, 2014. The Company’s filings with the Securities and Exchange Commission since June 10,
2014, have, where applicable, reflected this name change.

 January 20, 2015

 Page

 Three

•

Disclose the amount of statutory net income 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.

 In response to the Staff’s comment, the following disclosure will be added prospectively to the Company’s
Statutory Financial Information note in Form 10-K:

 The following is selected information for Global Indemnity Reinsurance, net of
intercompany eliminations, where applicable, as determined in accordance with the Bermuda Insurance Act 1978:

Years Ended December 31,

(Dollars in thousands)

2013

2012

2011

 Statutory capital and surplus, as of end of period

$
913,401

$
844,696

$
788,420

 Statutory net income (loss)

31,697

21,955

(63,429
)

•

Provide the disclosures required under ASC 944-505-50-2 through 50-6, as applicable.

The Company’s disclosure with respect to prescribed or permitted statutory accounting practices complies with the requirements of ASC
944-505-50-2 through 50-6. Specifically, the Company confirms that none of its reinsurance or insurance subsidiaries have any prescribed or permitted statutory accounting practices that meet the disclosure criteria in ASC 944-505-50-2 through 50-6
for any of the periods presented in the Company’s 2013 Form 10-K. As such, no additional disclosures under ASC 944-505-50-2 through 50-6 are applicable.

The Company is aware of its obligations under the Securities Exchange Act of 1934, as amended.

The Company acknowledges that:

•

it 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 taking any action with respect to the filing; and

•

the company may not assert staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws of the United States.

 January 20, 2015

 Page

 Four

 Please do not hesitate to call the undersigned at (610) 664-1500 with any questions or further comments
you may have regarding this filing or if you wish to discuss the above response.

 Very truly yours,

/s/ Thomas M. McGeehan

 Thomas M. McGeehan

cc:
Cynthia Y. Valko, Global Indemnity plc

CORRESP
1
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SEC Response Letter

 Linda Hohn

Vice President &

Associate General Counsel

 P:
610-660-6862

 F: 610-660-8887

lhohn@global-indemnity.com

 December 29, 2014

VIA EDGAR

 Mr. Jim B. Rosenberg

Senior Assistant Chief Accountant

 Division of Corporation
Finance

 Securities and Exchange Commission

 100 F Street,
N.E.

 Washington, D.C. 20549

Re:
Global Indemnity plc

 Form 10-K for the Fiscal Year Ended December 31, 2013

 Filed March 14, 2014

File No. 001-34809

 Dear
Mr. Rosenberg:

 We are writing to respond to the comment letter of the staff of the Securities and Exchange Commission, dated December 23, 2014,
relating to the above-referenced documents. In that letter, you asked that we respond to the comments within 10 business days or advise the staff when we will respond. We hereby confirm, per our discussion, that we currently expect to respond no
later than January 20, 2015. In the meantime, please do not hesitate to contact me. I can be reached at (610) 660-6862.

Sincerely,

 /s/ Linda C. Hohn

Linda C. Hohn

Vice President and Associate General Counsel

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

October  26, 2012

Via E -mail
Ms. Cynthia Y. Valko
Chief Executive Officer
Global Indemnity plc
Arthur Cox Building
Earlsfort Terrace
Dublin 2, Ireland

Re:  Global Indemnity plc
Form 10 -K for the Fiscal Year Ended December 31, 2011
Filed March 14, 2012
File No. 001 -34809

Dear Ms. Valko :

We have completed our review of your filings .  We remind you that  our comments or
changes to disclosure in response to our comments do not foreclose the Commission from taking
any action with respect to the company or the filing s and the company may not assert staff
comments as a defense in any proceeding initiated by t he Commission or any person under the
federal securities laws of the United States.  We urge all persons who are responsible for the
accuracy and adequacy of the disclosure in the filing s to be certain that the filing s include the
information the Securitie s Exchange Act of 1934 and all applicable rules require.

Sincerely,

 /s/ Daniel Greenspan for

Jeffrey Riedler
Assistant Director

CORRESP
1
filename1.htm

Correspondence

 October 9, 2012

 VIA EDGAR

 Mr. Jeffrey P. Riedler

Assistant Director

 Division of Corporation
Finance

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549

RE:
Global Indemnity plc

 Form 10-K
for the Fiscal Year Ended December 31, 2011

 Filed March 14, 2012

File No. 001-34809

 Dear
Mr. Riedler:

 On behalf of Global Indemnity plc (the “Company”), I am providing the following response to the additional
comment made in the Staff’s letter dated September 26, 2012 regarding the Company’s Annual Report on Form 10-K for the fiscal year ended December 31, 2011, filed on March 14, 2012. To assist in your review, the text of the
comment is repeated below with the Company’s response immediately following.

 General

1.
We note your response to our prior Comment 1 regarding disclosure of quantitative information by product line or groups of similar products. In your Business
section, you mention property, casualty, professional lines and general liability and in your MD&A section you also mention automobile liability, workers’ compensation and umbrella product lines. As we previously noted, the transcript of
your earnings call for the fiscal year ended December 31, 2011 indicates substantial interest in how the various product lines you offer affected your overall financial results for fiscal 2011. While it may not be feasible to disclose
profitability by product line or groups of similar products, as you have indicated that operating profitability is distinctly measured at the segment level, please consider reporting revenue-related information by product line or groups of similar
products. In this regard, please tell us what further information you may be able to include in future filings to present investors with a clearer picture of the revenue-generating performance of your various product lines and provide us with
proposed disclosure for future filings.

 In response to the Staff’s Comment, the Company, prospectively,
will include revenue-related information by product line or groups of similar products in tabular format within the MD&A section under the “Premiums” discussion for each segment and period. The following table disclosing gross written,
net written and net earned premiums by product line for each segment will be presented. If there are any significant fluctuations for these product lines, the reasons will be noted in paragraphs following the table.

(Dollars in thousands)

Quarter Ended September 30, 2012

Quarter Ended September 30, 2011

Gross Written

Net Written

Net Earned

Gross Written

Net Written

Net Earned

 Product Line or Group 1

$
xxx

$
xxx

$
xxx

$
xxx

$
xxx

$
xxx

 Product Line or Group 2

Xxx

Xxx

Xxx

Xxx

Xxx

Xxx

 Product Line or Group 3

Xxx

Xxx

Xxx

Xxx

Xxx

Xxx

 Total

$
xxx

$
xxx

$
xxx

$
xxx

$
xxx

$
xxx

 The Company believes that this tabular presentation of revenue-related information by product line will assist investors
in understanding the relationship between the Company’s various product lines and the overall financial results of the Company for a given period.

 The Company is aware of its obligations under the Securities Exchange Act of 1934, as amended.

The Company, as you requested, further acknowledges that:

•

 it is responsible for the adequacy and accuracy of the disclosure in the filings;

•

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the
filings; and

•

 the Company may not assert staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws
of the United States.

 Please do not hesitate to call the undersigned at (610) 664-1500 with any questions or further
comments you may have regarding this filing or if you wish to discuss the above response.

 Very truly yours,

/s/ Cynthia Y. Valko

 Cynthia Y. Valko

cc:
Nandini Acharaya, Attorney Advisor

 Thomas M. McGeehan, Global Indemnity plc

 Linda C. Hohn, Global Indemnity plc

September 26 , 2012

Via E -mail
Ms. Cynthia Y. Valko
Chief Executive Officer
Global Indemnity plc
Arthur Cox Building
Earlsfort Terrace
Dublin 2, Ireland

Re:  Global Indemnity plc
Form 10 -K for the Fiscal Year Ended December 31, 2011
Filed March 14, 2012
File No. 001 -34809

Dear Ms. Valko :

We have reviewed your filing  and your supplemental response  and have the following
comment .  In our comment  we may ask you to provide us with information so we may better
understand your disclosure.

Please respond to this letter within ten busines s days by providing the requested
information, or by advisi ng us when you will provide the requested response.   If you do not
believe our comment  applies to your facts and circumstance s, please tell us why in your
response.

After reviewing  the information you provide in response to our comment , we may have
additional comments.

General

1. We note your response to our prior Comment 1 regarding disclosure of quantitative
information by product line or groups of similar products.   In your Business section, you
mention property, casualty, professional lines and general liability and in your MD&A
section you also mention automobile liability, worker’s compensation and umbrella
product lines.  As we previously noted, the transcript of your earnings call for the fiscal
year en ded December 31, 2011 indicates substantial interest in how the various product lines
you offer affected your overall financial results for fiscal 2011 . While it may not be feasible
to disclose profitability by product line or groups of similar products, a s you have indicated
that operating profitability is distinctly measured at the segment level, please consider
reporting revenue -related information by product line or groups of similar products.   In
this regard, please tell us what further information you  may be able to include in future

Cynthia Y. Valko
Global Indemnity plc
September 26 , 2012
Page 2

 filings to present investors with a clearer picture of the revenue -generating performance
of your various product lines  and provide us with proposed disclosure for future filings .

We urge all persons who are responsible  for the accuracy and adequacy of the disclosure
in the filing to be certain that the filing includes the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   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 comments, 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 taking 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.

Please contact Nandini Acharya  at (202) 551 -3495  or me at (202) 551 -3715  with any
questions.

Sincerely ,

 /s/ Jeffrey P. Riedler

 Jeffrey P. Riedler
Assistant Director

CORRESP
1
filename1.htm

Correspondence

 August 22, 2012

VIA EDGAR

 Mr. Jim B.
Rosenberg

 Senior Assistant Chief Accountant

 Division of Corporation Finance

 United States Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549

RE:
Global Indemnity plc

 Form 10-K
for the Fiscal Year Ended December 31, 2011

 Filed March 14, 2012

Form 10-Q for the Quarterly Period Ended March 31, 2012

 Filed May 10, 2012

 File No. 001-34809

Dear Mr. Rosenberg:

 On behalf of Global
Indemnity plc (the “Company”), I am providing the following responses to the comments made in the Staff’s letter dated August 8, 2012 regarding the Company’s Annual Report on Form 10-K for the fiscal year ended
December 31, 2011, filed on March 14, 2012 and the Form 10-Q for the quarterly period ended March 31, 2012, filed on May 10, 2012. To assist in your review, the text of the comments are repeated below with the Company’s
response immediately following.

 Form 10-K for the Fiscal Year Ended December 31, 2011

General

1.
We note that throughout your filing you provide information primarily by your insurance and reinsurance segments. For example you provide quantitative information
such as gross and net premiums written, net premiums earned, income or loss from underwriting, loss ratio, expense ratio and combined ratio as well as qualitative information related to these measures on a segmental basis. Please consider also
providing information by material product lines or groups of similar or related product lines in future periodic reports and advise us as to your conclusions. Tell us what specific information you could provide on a product line basis or product
line group basis. In responding to this comment please consider and address the extent to which information by product line groups may be material to investors and how you have organized and conduct your business operations. In that regard we note
that the transcript of your earnings call for the fiscal year ended December 31, 2011 indicates substantial interest in how the various product lines you offer affected your financial results for fiscal 2011.

 The Company’s disclosures throughout the filing provide information on a segment basis
in accordance with FASB ASC 280-10-50. The guidance under FASB ASC 280-10-50 indicates that to be considered reportable operating segments, discrete financial information must be available and segment operating results need to be regularly reviewed
by the entity’s chief operating decision maker to allocate resources and assess performance.

 We believe reporting results
at the segment level is reasonable and appropriate given how the Company organizes and conducts its business. The Company’s chief operating decision maker regularly evaluates performance and has actively made the determination to allocate
resources at the segment level. Our Insurance Operations, which are located in the U.S., and Reinsurance Operations, which are located in Bermuda, each have their own infrastructure and management, and are engaged in distinct business activities
from which they earned revenues and incurred expenses. Within each operation, the products they sell share common costs, such as salary for underwriting personnel and allocated direct underwriting expenses (such as advertising costs, telephone, and
other fixed costs related to underwriting). The Company does not disaggregate this information at a product line level, so while management is able to review certain information at the product line level, actual operating profitability is distinctly
measured at the segment level. The Company may discuss product line information in certain areas of its 10-K or 10-Q when management has made the determination to evaluate information at this level and determined that the disclosure of such
information would be relevant and useful for investors.

 The Company does not believe there are currently relevant product line
disclosures that would be comparable between periods and consistent among filings to be useful and appropriate for investors. Therefore, the Company believes the disclosures it has provided in this regard in the referenced filings are reasonable and
appropriate.

 Exhibits

2.
The disclosure in your definitive proxy statement for your 2012 Annual General Meeting of Shareholders indicates that you have entered into employment agreements
with Ms. Valko and Messrs. Lebens and Devlin. Please amend your 10-k to file these agreements as exhibits.

 In the Company’s definitive proxy statement for its 2012 Annual General Meeting of Shareholders, the Company refers to and describes the Company’s employment arrangement with Ms. Valko and
Mr. Lebens, as the Company does not have traditional employment agreements with these executives. While there are no formal employment agreements between the Company and Ms. Valko or Mr. Lebens, and therefore no such agreements to
file as exhibits to an amended 10-K, the Company will amend its 10-K file as exhibits written descriptions of the Company’s employment arrangements with Ms. Valko and Mr. Lebens.

With respect to Mr. Devlin, the Company did not file its employment agreement with him with its 10-K as the Company had not made the
determination that Mr. Devlin was a named executive officer, as defined in Item 402 of Regulation S-K, until after the filing of the Company’s 10-K. As requested by the Staff, the Company will amend its 10-K to file
Mr. Devlin’s employment agreement as an exhibit.

 Financial Statements

 Note 10 Income Taxes, page 123

3.
You disclose current foreign and U.S. federal income tax expense (benefit) of $2.6 million, $5.4 million and $(5.3) million in 2011, 2010 and 2009, respectively.
Provide us with proposed disclosure to be included in future periodic reports that shows current income tax expense (benefit) of foreign and U.S. federal separately in accordance with Rule 4-08(h) of Regulation S-X. If foreign current income tax
expense is less than 5% of total current income tax expense for all periods, disclose that fact.

 In response
to the Staff’s comment, the Company will include the following language under the “Income Taxes” footnote in its financial statements, updated as appropriate, in future filings.

If the Company’s foreign current income tax expense is less than 5% of total current income tax expense, the following disclosure
will be presented:

 The Company’s foreign current income tax expense is less than 5% of total current income tax expense
for the quarter and nine months ended September 30, 2012.

 Should the Company’s foreign current income tax expense be
more than 5% of total current income tax during any period, the following disclosure will be presented:

Quarter Ended September 30,

Nine Months Ended September 30,

(Dollars in thousands)

2012

2011

2012

2011

 Non-U.S. current income tax expense (benefit)

$
xxx

$
xxx

$
xxx

$
xxx

 U.S. federal current income tax (benefit)

xxx

xxx

xxx

xxx

 Total current income tax expense (benefit)

xxx

xxx

xxx

xxx

 Note 11 Liability for Unpaid Losses and Loss Adjustment Expenses, page 126

4.
When explaining increases and decreases in prior year loss reserves you aggregate multiple loss years. For example, for 2011 professional liability you state
“The 4.4 million increase primarily related to our Insurance Operations and consisted of increases of $19.0 million related to accident years 1998, 2009 and 2010, offset partially by decreases of $13.2 million related to all other accident
years.” Provide us with proposed disclosure to be included in future periodic reports that disaggregates all increases and decreases discussed by accident year or tell us why you do not believe additional disclosure is warranted. Ensure your
disclosure also explains the underlying cause of the change, and that it clarifies the timing of the change in estimate such as why recognition occurred in the periods that it did and why recognition in earlier periods was not required. Explain, for
example, why you reduced general liability reserves for the 2009 accident year in 2010 and then increased reserves for the 2009 accident year in 2011.

 The Company believes it has disclosed changes to prior accident year loss reserves at a level that is relevant to an investor, including explanations as to the underlying causes of the changes. If the
ultimate loss estimates related to prior years changes, and if the reason why the estimate changed are the same for each of those accident years, one explanation for those years is provided. Significant increases and decreases in prior accident year
loss reserves are disclosed where warranted.

 The Staff noted the Company reduced general liability reserves for the 2009 accident year in
2010 and then increased reserves for the same 2009 accident year in 2011. Specifically, for the 2009 accident year general liability line, the 2010 reductions related to the Company’s overall general liability coverage, which had lower
frequency and severity during 2010 compared to initial indications. However, the Company’s construction defect coverage is evaluated separately but ultimately is included in the general liability line. During 2011, an extensive review of
construction defect coverage was performed and required an increase to loss reserves for the 2009 accident year.

 As an
accident year matures and more data becomes available, the Company may change its methodology or develop different approaches to reserving which would change its ultimate point estimate. The Company respectfully advises the Staff that it discloses
on pages 53 to 55 of its 2011 10-K under “Critical Accounting Estimates and Policies – Liability for Unpaid Losses and Loss Adjustment Expenses” that changes in reserving techniques or methodologies can have an impact on reserving
from year to year. In addition, a specific large claim may have an impact which would cause fluctuations in prior accident year reserves as more information about the claim comes to light. Lastly, there may be various coverages combined into one
product line which could cause increases and decreases to fall within the same product line accident year, even though the underlying cause relates to adjustments to specific coverages.

 Form 10-Q for the Quarterly Period Ended March 31, 2012

 Note 7 income
Taxes, page 24

5.
Regarding the tax rate reconciliation, explain in proposed disclosure to be included in future periodic reports why the line item “effective tax rate
adjustment” results in a reduction of $2.6 million in 2012 as compared to an increase of $1.5 million in 2011. Explain why the effective tax rate in 2012 is a 33.2% benefit on income before tax when your effective tax (benefit) rates in 2011,
2010, and 2009 were (5.6%), 9.5%, and 5.8%.

 In response to the Staff’s comment, the Company will
include the following disclosure in its “Income Taxes” footnote in its financial statements, updated as appropriate, in future filings:

Quarters Ended March 31,

(Dollars in thousands)

2012

2011

Amount

% of Pre-
Tax
Income

Amount

% of Pre-
Tax
Income

 Expected tax provision at weighted average rate

$
535

6.6
%

$
6,713

30.8
%

 Adjustments:

 Tax exempt interest

(407
)

(5.0
)

(524
)

(2.4
)

 Dividend exclusion

(235
)

(2.9
)

(157
)

(0.7
)

 Effective tax rate adjustment

(2,587
)

(31.7
)

1,471

6.7

 Other

(14
)

(0.2
)

21

0.1

 Income tax expense (benefit)

$
(2,708
)

(33.2
%)

$
7,524

34.5
%

 The effective income tax benefit rate for the quarter ended March 31, 2012 was 33.2%, compared to an
income tax expense rate of 34.5% for the quarter ended March 31, 2011. The decrease in the effective tax rate is primarily due to the Company’s settlement with AON in the

first quarter of 2011 as noted in the Company’s 2011 Form 10-K, as well as a decrease in realized gains and losses on the sale of securities. The tax rate on an interim basis is computed
using the expected annual effective rate. Any difference between the actual tax rate on an interim basis compared to the expected annual tax is reflected in the effective tax rate adjustment. The decline in the effective tax rate adjustment from
2011 to 2012 is primarily due to higher anticipated catastrophe losses in the US in 2012 when compared to the corresponding period in 2011. The effective rates differed from the weighted average expected income tax expense rates of 6.6% and 30.8%
for the quarter ended March 31, 2012 and 2011, respectively, primarily due to the fact that the Company records tax based on the annualized effective tax rate, net of tax-exempt interest and dividends.

In response to the Staff’s query regarding the effective tax rate benefit for 2012, underwriting results and investment income have
declined since 2009 and it currently expects its domestic insurance operations to incur a pre-tax loss in 2012. In 2011, the Company incurred operating losses; however, these losses were offset by net realized gains on the sale of securities as well
as the gain on the settlement with AON. In 2010 and 2009, the effective tax rate was driven by better operating results.

 The Company is aware
of its obligations under the Securities Exchange Act of 1934, as amended.

 The Company acknowledges that:

•

 it is responsible for the adequacy and accuracy of the disclosure in the filings;

•

 staff comments or changes to disclosure in response to staff comments do not foreclose the Commission from taking any action with respect to the
filings; and

•

 the company may not assert staff comments as a defense in any proceedings initiated by the Commission or any person under the federal securities laws
of the United States.

 Please do not hesitate to call the undersigned at (610) 664-1500 with any questions or further
comments you may have regarding this filing or if you wish to discuss the above response.

 Very truly yours,

/s/ Cynthia Y. Valko

 Cynthia Y. Valko

cc:
Joel Parker

 Tabatha Akins,
Staff Accountant

 Lisa Vanjoske, Assistant Chief Accountant

Nandini Acharaya, Attorney Advisor

 Jeffrey Riedler, Assistant Director

 Thomas M. McGeehan, Global Indemnity plc

 Linda C. Hohn, Global Indemnity plc

August 8 , 201 2

Via E -mail
Ms. Cynthia Y. Valko
Chief Executive Officer
Global Indemnity plc
Arthur Cox Building
Earlsfort Terrace
Dublin 2, Ireland

Re: Global Indemnity plc
 Form 10-K for the Fiscal Year Ended December 31, 2011
   Filed March 14 , 201 2
   Form 10 -Q for the Quarterly Period Ended March 31, 2012
   Filed May 10, 2012
File No. 001-34809

Dear Ms. Valko :

We have reviewed your filing s and have the following comments.  In our comments, 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 providing us the requested
information or by advising us wh en 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
responses to ou r comments.

After reviewing the information provided, we may raise additional comments and/or
request that you amend your filing s.

Form 10 -K for the Fiscal Year Ended December 31, 2011

General

1. We note that throughout your filing you provide information  primarily by your insurance and
reinsurance segments. For example you provide quantitative information such as gross and
net premiums written, net premiums earned, income or loss from underwriting, loss ratio,
expense ratio and combined ratio as well as q ualitative information related to these measures
on a segmental basis. Please consider also providing information by material product lines  or
groups of similar  or related product lines  in future periodic reports and advise us as to your
conclusions. Tell us what specific information you could provide  on a product line basis  or
product line group basis . In responding to this comment please consider and address the

Ms. Cynthia Y. Valko
Glob al Indemnity plc
August 8 , 2012
Page 2

 extent to which information by product line  or product line groups may be material to
investors and how you have organized and conduct your business operations. In that regard
we note that th e transcript of your earnings call for the fiscal year ended December 31, 2011
indicates substantial interest in how the various product lines you offer affected your
financial results for fiscal 2011.

Exhibits

2. The disclosure in your definitive proxy statement for your 2012 Annual General Meeting of
Shareholders indicates that you have entered into employment agreements with Ms. Valco
and Messrs. Lebens and Devlin. Please amend your 10 -k to file these agreements as exhibits.

Financial Statements
Note 10 Income Taxes, page 123

3. You disclose current foreign and U.S. federal income tax expense  (benefit)  of $2.6 million,
$5.4 million and $(5.3) million in 2011, 2010 and 2009, respectively.  Provide us with
proposed d isclosure to be included in future periodic reports that shows current income tax
expense (benefit) of foreign and U.S. federal separately in accordance with Rule 4 -08(h) of
Regulation S -X.  If foreign current income tax expense is less than 5% of total cu rrent
income tax expense for all periods, disclose that fact.

Note 11 Liability for Unpaid Losses and Loss Adjustment Expenses, page 126

4. When explaining increases and decreases in prior year loss reserves you aggregate multiple
loss years.  For example, for 2011 professional liability you state “The $4.4 million increase
primarily related to our Insurance Operations and consisted of increases of $19.0 million
related to accident years 1998, 2009 and 2010, offset partially by decreases of $13.2 million
related to all other accident years.”  Provide us with proposed disclosure to be included in
future periodic reports that disaggregates all increases and decreases discussed by accident
year or tell us why you do not believe additional disclosure is warranted .  Ensure your
disclosure also explains the underlying cause of the change, and that it clarifies the timing of
the change in estimate such as why recognition occurred in the periods that it did and why
recognition in earlier periods was not required.  Exp lain, for example, why you reduced
general liability reserves for the 2009 accident year in 2010 and then increased reserves for
the 2009 accident year in 2011.

Form 10 -Q for the Quarterly Period Ended March 31, 2012
Note 7 Income Taxes, page 24

5. Regarding the tax rate reconciliation, explain in proposed disclosure to be included in future
periodic reports why the line item “effective tax rate adjustment” results in a reduction of
$2.6 million in 2012 as compared to an increase of $1.5 million in 2 011.  Explain why the

Ms. Cynthia Y. Valko
Glob al Indemnity plc
August 8 , 2012
Page 3

 effective tax rate in 2012 is a 33.2% benefit  on income  before tax when your effective tax
(benefit) rates in 2011, 2010, and 2009 were (5.6%), 9.5%, and 5.8%.

We urge all persons who are responsible for the accuracy and adequacy of the disclosure
in the filing s to be certain that the filing s include the information the Securities Exchange Act of
1934 and all applicable Exchange Act rules require.   Since the company and its management are
in possession of all facts relating to a compa ny’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 s;
 staff comment s or changes to disclosu re in response to staff comment s do not foreclose
the Commission from taking any action with respect to the filing s; and
 the company may not assert staff comment s as a defense  in any proceeding initia ted by
the Commission or any person under the federal securities laws of the United States.

You may contact Tabatha Akins, Staff Accountant, at (202) 551 -3658 or Lisa Vanjoske,
Assistant Chief  Accountant, at (202) 551 -3614 if you have any questions regarding the
processing of your response as well as any questions regarding comments on the financial
statements and related matters.   Please contact Nandini Acharaya,  Attorney Advisor, at (202)
551-3495  or Jeffrey Riedler, Assistant Director, at (202) 551 -3715 with questions on comments
one and two .  In this regard, do not hesitate to contact me at (202) 551 -3679.

Sincerely,

  /s/ Joel Parker for

Jim B. Rosenberg
Senior Assistant Chief Accountant

CORRESP
1
filename1.htm

Correspondence to the Securities and Exchange Commission

 Skadden, Arps, Slate, Meagher & Flom LLP

525 University Avenue, Suite 1100

 Palo Alto, CA 94301

 June 18, 2012

 VIA
EDGAR, FACSIMILE AND FEDERAL EXPRESS

 Christina Chalk

 Senior Special Counsel

 Office of Mergers and Acquisitions

United States Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549-3628

Re:
Global Indemnity plc

 Schedule
TO-I/A

 Filed June 14, 2012

 File No. 5-85996

 Dear Ms. Chalk:

On behalf of our client, Global Indemnity plc, a company formed under the laws of Ireland (the “Company”), set forth below is
our response to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) received orally on June 18, 2012 regarding the Schedule TO-I/A filed by the Company on June 14, 2012
(the “Schedule TO-I/A”).

 The Company acknowledges that its reference to the “safe harbor” provisions of
the Private Securities Litigation Reform Act of 1995 (“PSLRA”) in the Company’s press releases attached as exhibits to Schedule TO-I and its amendments (the “Press Releases”) was erroneous. The Company further acknowledges
that any forward-looking statements made in the Press Releases in connection with the tender offer are not covered by the PSLRA. The Company supplementally informs the Staff that to the extent that there were any forward looking statements in the
Press Releases, such statements are no longer forward-looking as the Company has completed the tender offer and has paid for all purchased shares.

 Christina Chalk

 June 18, 2012

 Page 2

 *
*         *

 If you have any questions or require any further information with regard
to the foregoing, please in the first instance contact the undersigned by phone at (650) 470-4522.

Very truly yours,

/s/ Thomas J.
Ivey

Thomas J. Ivey

cc:
Tom McGeehan

 2

CORRESP
1
filename1.htm

SEC Correspondence

 Skadden, Arps, Slate, Meagher & Flom LLP

525 University Avenue, Suite 1100

 Palo Alto, CA 94301

 May 21, 2012

VIA EDGAR, FACSIMILE AND FEDERAL EXPRESS

Christina Chalk

 Senior Special Counsel

 Office of Mergers and Acquisitions

United States Securities and Exchange Commission

100 F Street, N.E.

 Washington, D.C. 20549-3628

Re:
Global Indemnity plc

Schedule TO-I

Filed May 9, 2012

File No. 5-85996

 Dear Ms. Chalk:

 On behalf of our client, Global Indemnity plc, a company formed under the laws of Ireland (the “Company”), set
forth below are responses to the comments of the staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated May 17, 2012 (the “Comment Letter”) regarding the
Schedule TO-I filed by the Company on May 9, 2012 (the “Schedule TO”). The numbered paragraphs below correspond to the numbered paragraphs in the Comment Letter. To facilitate your review, we have reproduced the text of the
Staff’s comments in italics below.

 The Company is filing, via EDGAR submission, Amendment No. 1 to the Schedule TO
(“Amendment No. 1”) concurrently with the submission of this response letter.

 Schedule TO – Item 10. Financial
Statements

1.
Please explain in your response letter why you do not believe that the financial information showing the pro forma effect of the tender offer on the Company is
material. See Item 1010(b) of Regulation M-A. In this regard, we note that if fully subscribed, you would be repurchasing more than 19% of the Company’s A ordinary Shares in the offer.

Response: The Company does not believe that the pro forma financial information described in Item 1010(b) of Regulation M-A is
material under the

 Christina Chalk

 May 21, 2012

 Page 2

circumstances. The Company notes that Instruction 2 to Item 10 of Schedule TO indicates that financial statements are not material to a tender offer if (i) the consideration offered
consists solely of cash, (ii) there is no financing condition to the offer and (iii) the offeror is a public reporting company under Section 13(a) or 15(d) of the Securities Exchange Act of 1934, as amended, that files reports
electronically on EDGAR. The Company confirms to the Staff that all three of these conditions are satisfied in the present tender offer. In addition, the Company notes that it does not intend to borrow in order to fund the tender offer. As such,
there will be a minimal impact on the Company’s financial statements as a result of the tender offer. The tender offer will have the following impact on the Company’s financial statements, (a) the Company’s cash and investments
will decrease by the total amount of funds used by the Company to consummate the Offer, including the payment of fees and expenses in connection with the Offer, (b) total stockholders’ equity will decrease by the amount of funds used to
pay for the Shares acquired in the Offer and fees and expenses incurred in connection with the Offer, (c) the number of outstanding A ordinary shares of the Company will be decreased by the number of Shares acquired in the Offer, and
(d) earnings/loss per Share at any given level of net income/loss of the Company will increase proportionately by virtue of the decrease in A ordinary shares outstanding. As a consequence, the Company does not feel that a presentation of pro
forma financial statements would be material to an investor. However, in the interest of full disclosure, the Company has amended the Offer to Purchase to (x) renumber Section 17 (“Miscellaneous”) as Section 18, (y) add
a new Section 17 (“Financial Information”) to provide the following disclosure regarding the impact of the Offer on the Company’s financial statements and (z) add a corresponding question and answer in the Summary Term Sheet
in the Offer to Purchase to summarize such financial information:

 The consummation of the Offer will have the following effect
on the Company’s financial statements:

 (i) the Company’s cash and investments will decrease by the total amount of
funds used by the Company to consummate the Offer, including the payment of fees and expenses in connection with the Offer;

(ii) total stockholders’ equity will decrease by the amount of funds used to pay for the Shares acquired in the Offer and fees and
expenses incurred in connection with the Offer;

 (iii) the number of outstanding Shares of the Company will be decreased by the
number of Shares acquired in the Offer; and

 2

 Christina Chalk

 May 21, 2012

 Page 3

 (iv) earnings/loss per Share at any given level of net income/loss of the Company will
increase proportionately by virtue of the decrease in Shares outstanding.

 Offer to Purchase – General

2.
Global Indemnity is using a modified “Dutch auction” mechanism for this offer, whereby the offer materials disclose a range of prices from $19.25 through
$22.00 per Share at which tendering holders may elect for the Company to repurchase their tendered A ordinary Shares. Disclosure in the Offer to Purchase indicates that the trading price of the A ordinary Shares on the last full trading day before
the announcement of this offer was $19.34 per Share. Therefore, at the low end, the specified range in the modified Dutch auction is below the most recent trading price of the Shares. Tendering holders who do not specify a tender price, who make
Purchase Price Tenders and those who elect to tender at the bottom of the range will therefore be paid a price per Share that is below the most recent market price per share before announcement of the offer. We have stated that a bidder must clearly
disclose when the offer price is below the recent market price for the subject securities. See Commission Guidance on Mini-Tender Offers and Limited Partnership Tender Offers, SEC Release No. 34-43069 (July 31, 2000). Please amend to note that
Purchase Price Tenders or those who specify a tender price of $19.25 will receive less than the most recent trading price for the Shares.

 Response: In response to the Staff’s comment, the Company has amended the Offer to Purchase in the following sections to note that the Purchase Price may be less than the closing market price
of $19.34 per Share on May 8, 2012, the last full trading day before the announcement of the offer:

•

 the first paragraph under “What will be the Purchase Price for the Shares and what will be the form of payment?” in the Summary Term Sheet of
the Offer to Purchase;

•

 the paragraph under “What is the recent market price for the Shares?” in the Summary Term Sheet of the Offer to Purchase;

•

 the second to last paragraph under Introduction of the Offer to Purchase; and

•

 the third paragraph in Section 3 (“Procedure for Tendering Shares.”) of the Offer to Purchase.

 3

 Christina Chalk

 May 21, 2012

 Page 4

 How many Shares is Global Indemnity offering to purchase?, page i

3.
On the cover page of the Offer to Purchase and elsewhere in that document, you state that the Company “is offering to purchase up to 3,168,831 of its A ordinary
shares…” However, in this section, you state that you will purchase properly tendered Shares “up to a maximum aggregate purchase price of $61,000,000.” If 3,168,831 Shares are tendered at the top end of the purchase price range
($22.00 per Share), the aggregate total funds needed to purchase all tendered Shares would be $69,714,282. Therefore, the disclosure about the maximum number of Shares to be purchased in the offer is confusing and should be revised. Revise to state
the maximum as a dollar amount or as a set number of Shares.

 Response: In response to the
Staff’s comment, the Company has amended the Offer to Purchase throughout to state the maximum as a dollar amount and delete references to the maximum number of Shares except in the first paragraph under “How many Shares is Global
Indemnity offering to purchase?” in the Summary Term Sheet of the Offer to Purchase, the third to last paragraph under Introduction in the Offer to Purchase and, the first paragraph in Section 11 (“Interests of Directors and Executive
Officers; Transactions and Arrangements Concerning the Shares.”) of the Offer to Purchase.

4.
The disclosure in the last sentence in the first paragraph of this section is confusing. You state that if the offer is fully subscribed and the purchase price is at
the top of the range ($22.00 per Share), “the minimum number of Shares that will be purchased under the Offer is 2,772,727.” It appears that this is the maximum number of Shares that would be purchased, or stated differently, it would be
the total number of Shares purchased. The use of the term “minimum” implies that more Shares could or would be purchased if the offer price is $22.00 per Share; from the disclosure concerning your maximum aggregate purchase price of
$61,000,000 cited in our comment above, this does not appear to be the case. Please revise or advise.

Response: In response to the Staff’s comment, the Company has amended the Offer to Purchase to revise the last two sentences
in the first paragraph of this section to read “If the Purchase Price is determined to be $19.25 per Share, the minimum Purchase Price under the Offer, the total number of Shares that will be purchased under the Offer is 3,168,831. Assuming
that the Offer is fully subscribed, if the Purchase Price is determined to be $22.00 per Share, the maximum Purchase Price under the Offer, the total number of Shares that will be purchased under the Offer is 2,772,727.” The Company has made a
conforming change in the first paragraph of Section 11 of the Offer to Purchase.

 4

 Christina Chalk

 May 21, 2012

 Page 5

*        *        *

In response to the Staff’s request, the Company is also concurrently filing an acknowledgment letter from Thomas McGeehan, Chief
Financial Officer of the Company, with respect to certain matters.

 If you have any questions or require any further
information with regard to the foregoing, please in the first instance contact the undersigned by phone at (650) 470-4522.

Very truly yours,

/s/ Thomas J. Ivey

Thomas J. Ivey

cc:
Tom McGeehan

 5

CORRESP
1
filename1.htm

SEC Correspondence

 Global Indemnity plc

 Arthur Cox Building, Earlsfort Terrace

 Dublin 2, Ireland

May 21, 2012

 VIA EDGAR, FACSIMILE AND FEDERAL EXPRESS

 Christina Chalk

Senior Special Counsel

 Office of Mergers and
Acquisitions

 United States Securities and Exchange Commission

 100 F Street, N.E.

 Washington, D.C. 20549-3628

Re:
Global Indemnity plc

Schedule TO-I

Filed May 9, 2012

File No. 5-85996

 Dear Ms. Chalk:

 In response to the request of the staff (the “Staff”) of the Securities and Exchange Commission (the
“Commission”) contained in your letter dated May 17, 2012 regarding the Schedule TO-I filed by Global Indemnity plc (the “Company”) on May 9, 2012, the Company hereby acknowledges that:

(1)
the Company is responsible for the adequacy and accuracy of the disclosure in the filing;

(2)
Staff comments or changes to disclosure in response to Staff comments do not foreclose the Commission from taking any action with respect to the filing; and

(3)
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.

GLOBAL INDEMNITY PLC

By:

 /s/ Thomas M. McGeehan

Name:

Thomas M. McGeehan

Title:

Chief Financial Officer

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE

 May 17, 2012

Via Email
Thomas Ivey Skadden, Arps, Slate, Meagher & Flom LLP 535 University Avenue, Suite 1100 Palo Alto, CA 94301
Re:  Global Indemnity plc
Schedule TO-I Filed May 9, 2012
 SEC File No. 5-85996

Dear Mr. Ivey:
The staff in the Office of Mergers and Ac quisitions in the Division of Corporation
Finance has conducted a limited review of th e filing listed above. The scope of our
review is limited to the matters identifie d below. All defined terms have the same
meaning as in your filing, unless otherwise noted.
 Please respond to this letter promptly  by amending your filing, by providing the
requested information, or by advising us when you will provide the requested response. 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 filing and the information you provide in
response to these comments, we may have additional comments.  In some of our comments, we may ask you to provide us w ith information so we may better understand
your disclosure.   Schedule TO – Item 10. Financial Statements

1. Please explain in your response letter w hy you do not believe that the financial
information showing the pro forma effect  of the tender offer on the Company is
material. See Item 1010(b) of Regulation M-A.  In this regard, we note that if fully
subscribed, you would be repurchasing more than 19% of the Company’s A ordinary
Shares in the offer.

Thomas Ivey, Esq.
Skadden, Arps, Slate, Meagher & Flom LLP May 17, 2012 Page 2

 Offer to Purchase - General

 2. Global Indemnity is using a modified “Dut ch auction” mechanism for this offer,
whereby the offer materials disclose a range of prices from $19.25 through $22.00
per Share at which tendering holders ma y elect for the Company to repurchase
their tendered A ordinary Shares. Disclosu re in the Offer to Purchase indicates
that the trading price of the A ordinary Shares on the last full trading day before
the announcement of this offer was $19.34 pe r Share. Therefore, at the low end,
the specified range in the modified Dutch auction is below the most recent trading
price of the Shares. Tendering holders who do not specify a tender price, who
make Purchase Price Tenders and those w ho elect to tender at the bottom of the
range will therefore be paid a price per Sh are that is below the most recent market
price per share before announcement of the offer. We have stated that a bidder
must clearly disclose when the offer pri ce is below the recent market price for the
subject securities. See Commission Guidan ce on Mini-Tender Offers and Limited
Partnership Tender Offers, SEC Release No. 34-43069 (July 31, 2000). Please
amend to note that Purchase Price Tenders  or those who specify a tender price of
$19.25 will receive less than th e most recent trading price for the Shares.
 How many Shares is Global Indemnity  offering to purchase?, page i

3. On the cover page of the Offer to Purc hase and elsewhere in that document, you
state that the Company “is offering to purchase up to 3,168,831 of its A ordinary
shares…” However, in this section, you state that you will purchase properly
tendered Shares “up to a maximum a ggregate purchase pr ice of $61,000,000.” If
3,168,831 Shares are tendered at the top end of the purchas e price range ($22.00
per Share), the aggregate total funds n eeded to purchase all tendered Shares
would be $69,714,282.  Therefore, the disclo sure about the maximum number of
Shares to be purchased in the offer is confusing and should be revised. Revise to
state the maximum as a dollar amount or as a set number of Shares.

4. The disclosure in the last sentence in the first paragraph of  this section is
confusing. You state that if the offer is fully subscribed and the purchase price is
at the top of the range ($ 22.00 per Share), “the minimum number of Shares that
will be purchased under the Offer is 2,772,727.”   It appears that this is the
maximum  number of Shares that would be purchased, or stated differently, it
would be the total number of  Shares purchased. The use of the term “minimum”
implies that more Shares could or woul d be purchased if the offer price is $22.00
per Share; from the disclosure conc erning your maximum aggregate purchase
price of $61,000,000 cited in our comment above, this does not appear to be the case. Please revise  or advise.

Thomas Ivey, Esq.
Skadden, Arps, Slate, Meagher & Flom LLP May 17, 2012 Page 3

Closing Information

Please amend the Schedule TO-I in response to these comments. We may have
further comments upon receipt of your amendmen t; therefore, please allow adequate time
after the filing of the amendm ent for further staff review.

You should furnish a respons e letter with the amendm ent keying your responses
to our comment letter and providing any suppl emental information we have requested.
You should transmit the letter via EDGAR under the label “CORRESP.”  In the event
that you believe that compliance with any of the above comments is inappropriate,
provide a basis for such belief to the staff in the response letter.
 We urge all persons who are responsible for the accuracy and adequacy of the
disclosure in the filing review ed by the staff to be certain that they have provided all
information investors require for an info rmed decision.  Since the company is in
possession of all facts relating to its disclosu re, it is responsible for the accuracy and
adequacy of the disclosures it has made.     In connection with responding to our comments, please provide, in writing, a
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 taking any action with respect to the filing; and

 the Company may not assert staff comme nts as a defense in any proceeding
initiated by the Commission or any person under the federal secu rities laws of the
United States.

Thomas Ivey, Esq.
Skadden, Arps, Slate, Meagher & Flom LLP May 17, 2012 Page 4

  In addition, please be advi sed that the Division of En forcement has access to all
information you provide to the staff of the Divi sion of Corporation Fi nance in our review
of your filing or in response to our comments on your filing.
 Please direct any questions about these comments or your filing to me at 202-551-
3263.

Sincerely,  /s/ Christina Chalk  Christina Chalk Senior Special Counsel Office of Mergers and Acquisitions

CORRESP
1
filename1.htm

corresp

July 20, 2011

 VIA FACSIMILE AND EDGAR

                         Re:

    Global Indemnity plc

Registration Statement on Form S-3

Filed July 19, 2011

File No.: 333-175391

Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

    Attention:

    Jeffrey P. Riedler, Assistant Director

Johnny Gharib

Ladies and Gentlemen:

     Pursuant to Rule 461 under the Securities Act of 1933 (the “Securities Act”), as amended,
Global Indemnity plc (the “Company”) hereby requests that the effective date of the
above-referenced Registration Statement be accelerated so that it may
become effective at 2 p.m.,
Washington, D.C. time, on July 21, 2011, or as soon as possible thereafter. In this regard, the
Company is aware of its obligations under the Securities Act.

     The Company acknowledges that:

    •

    should the Securities and Exchange Commission (the “Commission”) or the staff of
the Commission (the “Staff”), acting pursuant to delegated authority, declare the
filing effective, it does not foreclose the Commission from taking any action with
respect to the filing;

    •

    the action of the Commission or the Staff, acting pursuant to delegated
authority, in declaring the filing effective, does not relieve the Company from its
full responsibility for the adequacy and accuracy of the disclosure in the filing;
and

    •

    the Company may not assert staff comments and the declaration of effectiveness
as a defense in any proceeding initiated by the Commission or any person under the
federal securities laws of the United States.

    Very truly yours,

Global Indemnity plc

    By:

/s/
Thomas M. McGeehan

    Name:
    Thomas M. McGeehan

    Title:
    Senior Vice President and
Chief Financial
Officer

July 13, 2011
 Via E-mail

Larry A. Frakes Chief Executive Officer Global Indemnity PLC
Arthur Cox Building
Earlsfort Terrace Dublin 2 Ireland
Re: Global Indemnity PLC
  Registration Statement on Form S-3
Filed July 7, 2011
  File No. 333-175391

Dear Mr. Frakes:
 We have limited our review of your registrati on statement to the issue we have addressed
in our comment.  In our comment, 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.  Where you do not believe our comment applies 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 re gistration statement and the information you
provide in response to this comment, we may have additional comments.

 General

1. We note that you have incorporated by reference the company’s 2010 Form 10-K,
March 31, 2011 Form 10-Q and several curr ent reports on Form 8-K.  However, you
have not incorporated by reference th e Item 8.01 Form 8-K filed April 28, 2011.
Please amend your registration statement to  incorporate by reference the Form 8-K
filed April 28, 2011.

We urge all persons who are responsible for th e accuracy and adequacy of the disclosure
in the filing to be certain that the filing incl udes the information the Securities Act of 1933 and
all applicable Securities Act rules require.  Since the company and its management are in
possession of all facts relating to a company’s disc losure, they are responsible for the accuracy
and adequacy of the disclosures they have made.

Larry A. Frakes Global Indemnity PLC July 13, 2011 Page 2

Notwithstanding our comment, in the event you request acceleration of the effective date
of the pending registration statement please pr ovide a written statement from the company
acknowledging that:

 should the Commission or the staff, acting purs uant to delegated authority, declare the
filing effective, it does not foreclose the Co mmission from taking any action with respect
to the filing;

 the action of the Commission or the staff, acting pursuant to delegated authority, in
declaring the filing effective, does not relieve the company from its full responsibility for
the adequacy and accuracy of the disclosure in the filing; and

 the company may not assert staff comments a nd the declaration of effectiveness as a
defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.  Please refer to Rules 460 and 461 regarding re quests for acceleration.  We will consider a
written request for acceleration of  the effective date of the regi stration statement as confirmation
of the fact that those reques ting acceleration are aware of thei r respective responsibilities under
the Securities Act of 1933 and the Securities Excha nge Act of 1934 as they relate to the proposed
public offering of the securities specified in th e above registration stat ement.  Please allow
adequate time for us to review any amendment prior to the requested effective date of the
registration statement.

Please contact Johnny Gharib at (202) 551- 3170 or me at (202) 551-3715 with any
questions.
Sincerely,
   /s/ Jeffrey P. Riedler    Jeffrey Riedler
Assistant Director