SecProbe.io

<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<FILENAME>filename2.txt
<TEXT>
 May 5, 2025

Christopher Masterson
Chief Financial Officer, Treasurer and Secretary
Global Net Lease, Inc.
650 Fifth Avenue, 30th Floor
New York, NY 10019

 Re: Global Net Lease, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 File No. 001-37390
Dear Christopher Masterson:

 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 Real Estate &
Construction
</TEXT>
</DOCUMENT>

CORRESP
 1
 filename1.htm

 May 2, 2025

 VIA EDGAR

 Mr. Frank Knapp

 Ms. Jennifer Monick

 Office of Real Estate & Construction

 U.S. Securities and Exchange Commission

 Washington, D.C. 20549

 Re:
 Global Net Lease, Inc.

 Form 10-K for fiscal year ended December 31, 2024

 Filed February 27, 2025

 File No. 001-37390

 Dear Mr. Knapp and Ms. Monick:

 On behalf of Global Net Lease, Inc. (the " Company "),
set forth below is the Company's response to the comment of the staff (the " Staff ") of the Securities and Exchange
Commission (the " Commission ") contained in your letter to Christopher Masterson of the Company, dated April 30, 2025
(the " April 30 th Letter "). For convenience of reference, the Staff's comment contained in the
April 30 th Letter is reprinted below in bold type and is followed by the corresponding response of the Company.

 Form 10-K for fiscal year ended December 31, 2024

 Item 7. Management's Discussion and Analysis of Financial
Condition and Results of Operations

 Results of Operations

 Comparison of the Year Ended December 31, 2024 to the Year Ended
December 31, 2023,

 page 48

 1.

 We note you have identified multiple factors that impact your
 operating results but it does not appear that you have separately quantified each factor. For example purposes only, you state that
 the decrease in revenue in your office segment was primarily driven by dispositions during the year ended December 31, 2024,
 partially offset by a full period of revenue in the year ended December 31, 2024 attributable to properties acquired from RTL on the
 Acquisition Date for the year ended December 31, 2024. When there are multiple factors impacting your operating results, please
 revise your disclosures in future periodic filings to separately quantify the impact from each factor.

 The Company acknowledges the Staff's comment and advises the
Staff that it will make the requested revisions to the Company's disclosure in the Company's Form 10-Q for the quarter ended
March 31, 2025 and in future filings with the Commission.

 *************

 Mr. Frank Knapp

 Ms. Jennifer Monick

 U.S. Securities and Exchange Commission

 May 2, 2025

 Page 2

 Please feel free to contact me at (332) 265-2074 should you require
additional information or have any questions.

 Sincerely,

 GLOBAL NET LEASE, INC.

 By:
 /s/ Christopher Masterson

 Christopher Masterson

 Chief Financial Officer

 Cc:
 Joseph A. Herz and Win Rutherfurd, Greenberg Traurig, LLP

 Dana Van Wie, PricewaterhouseCoopers, LLP

<DOCUMENT>
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<TEXT>
 April 30, 2025

Christopher Masterson
Chief Financial Officer, Treasurer and Secretary
Global Net Lease, Inc.
650 Fifth Avenue, 30th Floor
New York, NY 10019

 Re: Global Net Lease, Inc.
 Form 10-K for the Fiscal Year Ended December 31, 2024
 File No. 001-37390
Dear Christopher Masterson:

 We have limited our review of your filing to the financial statements
and related
disclosures and have the following comment.

 Please respond to this letter within ten business days by providing the
requested
information or advise us as soon as possible when you will respond. If you do
not believe
the comment applies to your facts and circumstances, please tell us why in your
response.

 After reviewing your response to this letter, we may have additional
comments.

Form 10-K for the fiscal year ended December 31, 2024
Item 7. Management's Discussion and Analysis of Financial Condition and Results
of
Operations
Results of Operations
Comparison of the Year Ended December 31, 2024 to the Year Ended December 31,
2023,
page 48

1. We note you have identified multiple factors that impact your operating
results but it
 does not appear that you have separately quantified each factor. For
example purposes
 only, you state that the decrease in revenue in your office segment was
primarily
 driven by dispositions during the year ended December 31, 2024,
partially offset by a
 full period of revenue in the year ended December 31, 2024 attributable
to properties
 acquired from RTL on the Acquisition Date for the year ended December
31,
 2024. When there are multiple factors impacting your operating results,
please revise
 your disclosures in future periodic filings to separately quantify the
impact from each
 factor.
 April 30, 2025
Page 2

 In closing, 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 Frank Knapp at 202-551-3805 or Jennifer Monick at
202-551-3295
with any questions.

 Sincerely,

 Division of
Corporation Finance
 Office of Real Estate
& Construction
</TEXT>
</DOCUMENT>

United States securities and exchange commission logo
April 30, 2024
Christopher Masterson
Chief Financial Officer, Treasurer and Secretary
Global Net Lease, Inc.
650 Fifth Ave., 30th Floor
New York, NY 10019
Re:Global Net Lease, Inc.
Form 10-K for fiscal year ended December 31, 2023
Filed February 27, 2024
File No. 001-37390
Dear Christopher Masterson:
            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 Real Estate & Construction

CORRESP
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April 26, 2024

VIA EDGAR

Mr. Paul Cline

Mr. Mark Rakip

Office of Real Estate & Construction

U.S. Securities and Exchange Commission

Washington, D.C. 20549

    Re:
    Global Net Lease, Inc.

    Form 10-K for fiscal year ended December 31, 2023

    Filed February 27, 2024

    File No. 001-37390

Dear Mr. Cline and Mr. Rakip:

On behalf of Global Net Lease, Inc. (the “Company”),
set forth below are the Company’s responses to the comments of the staff (the “Staff”) of the Securities and
Exchange Commission (the “Commission”) contained in your letter to Christopher Masterson of the Company, dated April
16, 2024 (the “April 16th  Letter”). For convenience of reference, the Staff’s comments contained
in the April 16th Letter are reprinted below in bold type and are followed by the corresponding response of the Company.

Form 10-K for fiscal year ended December 31, 2023

Consolidated Financial Statements

Notes to Consolidated Financial Statements

Note 15 - Segment Reporting, page F-52

1.
We note that as a result of the mergers and the related strategic shift in your operations, you concluded you now operate in four reportable segments. Please revise your disclosure in future periodic filings to address the following or advise:

  ·
  Revise the title your segment measure of profit or loss to net operating income or a similarly-titled measure
  so as to better reflect both the revenue and property operating expense components of your segment measure; and

  ·
  We note you reconcile your segment measure of profit or loss to Net loss attributable to common stockholders, and not Net (loss)
  income before income tax. In future filings, revise your reconciliation to reconcile your segment measure to Net (loss) income before
  income tax; refer to ASC 280-10-50-30b.

Mr. Paul Cline

Mr. Mark Rakip

U.S. Securities and Exchange Commission

April 26, 2024

Page 2

The Company acknowledges the Staff’s comment and advises the
Staff that it will make the requested revisions to the Company’s disclosure in the Company’s Form 10-Q for the quarter ended
March 31, 2024 and in future filings with the Commission.

*************

Please feel free to contact me at (332) 265-2074 should you require
additional information or have any questions.

Sincerely,

GLOBAL NET LEASE, INC.

    By:
    /s/
    Christopher Masterson

    Christopher Masterson

    Chief Financial Officer

    Cc:
    Joseph A. Herz, Greenberg Traurig, LLP

    William A. Staffieri, PricewaterhouseCoopers, LLP

United States securities and exchange commission logo
April 16, 2024
Christopher Masterson
Chief Financial Officer, Treasurer and Secretary
Global Net Lease, Inc.
650 Fifth Ave., 30 Floor
New York, NY 10019
Re:Global Net Lease, Inc.
Form 10-K for fiscal year ended December 31, 2023
Filed February 27, 2024
File No. 001-37390
Dear Christopher Masterson:
            We have limited our review of your filing to the financial statements and related
disclosures and have the following comment(s).
            Please respond to this letter within ten business days by providing the requested
information or advise us as soon as possible when you will respond. If you do not believe a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments.
Form 10-K for fiscal year ended December 31, 2023
Consolidated Financial Statements
Notes to Consolidated Financial Statements
Note 15 - Segment Reporting, page F-52
1.We note that as a result of the mergers and the related strategic shift in your operations,
you concluded you now operate in four reportable segments.  Please revise your
disclosure in future periodic filings to address the following or advise:
•Revise the title your segment measure of profit or loss to net operating income or a
similarly-titled measure so as to better reflect both the revenue and property operating
expense components of your segment measure; and
•We note you reconcile your segment measure of profit or loss to Net loss attributable
to common stockholders, and not Net (loss) income before income tax.  In future
filings, revise your reconciliation to reconcile your segment measure to Net (loss)
income before income tax; refer to ASC 280-10-50-30b.

 FirstName LastNameChristopher Masterson
 Comapany NameGlobal Net Lease, Inc.
 April 16, 2024 Page 2
 FirstName LastName
Christopher Masterson
Global Net Lease, Inc.
April 16, 2024
Page 2
            In closing, 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 Paul Cline at 202-551-3851 or Mark Rakip at 202-551-3573 with any
questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction

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GLOBAL NET LEASE, INC.

650 Fifth Avenue, 30th Floor

New York, New York 10019

July 17, 2023

VIA
EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

Office of Real Estate and Construction

100 F Street, N.E.

Washington, D.C.  20549

Attention: Catherine De Lorenzo

    Re:
    Global Net Lease, Inc.

    Registration Statement on Form S-4

    Filed July 6, 2023

    File No. 333-273156

Acceleration Request:

    Requested Date:
    July 18, 2023

    Requested Time: 4:00 p.m. Eastern Time

Dear Ms. De
Lorenzo:

Pursuant
to Rule 461 of Regulation C promulgated under the Securities Act of 1933, as amended, Global Net Lease, Inc. (the “Company”)
hereby respectfully requests acceleration of the effective date of the above-referenced Registration Statement on Form S-4 (File
No. 333-273156) filed by the Company with the U.S. Securities and Exchange Commission on July 6, 2023, as amended on July 17,
2023 (the “Registration Statement”) so that it may become effective at the “Requested Date” and “Requested
Time” set forth above, or as soon thereafter as practicable.

Please call Michael J. Choate of Proskauer Rose
LLP at (312) 962-3567 to provide notice of the effectiveness of the Registration Statement.

    GLOBAL NET LEASE, INC.

    By:
     /s/ James L. Nelson

    Name:  James L. Nelson

    Title:    Chief Executive Officer and
    President

United States securities and exchange commission logo
July 13, 2023
James L. Nelson
Chief Executive Officer
Global Net Lease, Inc.
650 Fifth Avenue, 30th Floor
New York, NY 10019
Re:Global Net Lease, Inc.
Registration Statement on Form S-4
Filed July 6, 2023
File No. 333-273156
Dear James L. Nelson:
            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 Catherine De Lorenzo at 202-551-4079 with any questions.
Sincerely,
Division of Corporation Finance
Office of Real Estate & Construction
cc:       Michael J. Choate, Esq.

United States securities and exchange commission logo
March 30, 2023
Jeffrey D. Marell
Partner
Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas
New York, NY 10019
Re:Global Net Lease, Inc.
PREC14A filed March 22, 2023
File No. 001-37390
Dear Jeffrey D. Marell:
            We have reviewed your filing 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 these comments by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comments apply to your facts
and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
PREC14A filed March 22, 2023
General
1.Please outline briefly the rights of appraisal or similar rights of dissenters with respect to
any matter to be acted upon at the meeting and indicate any statutory procedure required
to be followed by dissenting security holders in order to perfect such rights.  See Item 3 of
Schedule 14A.
2.We note references in the proxy statement and form of proxy to "Rule 14(a)-4(c)."  Please
correct such references to "Rule 14a-4(c)."
Stockholder Proposals for the 2024 Annual Meeting, page 41
3.Please correct the typo in the penultimate sentence on page 41.
            We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

 FirstName LastNameJeffrey D. Marell
 Comapany NamePaul, Weiss, Rifkind, Wharton & Garrison LLP
 March 30, 2023 Page 2
 FirstName LastName
Jeffrey D. Marell
Paul, Weiss, Rifkind, Wharton & Garrison LLP
March 30, 2023
Page 2
            Please direct any questions to David Plattner, at 202-551-8094, or Christina Chalk, at
202-551-3263.
Sincerely,
Division of Corporation Finance
Office of Mergers and Acquisitions

United States securities and exchange commission logo
December 12, 2022
Lawrence S. Elbaum, Esq.
Partner
Vinson & Elkins LLP
The Grace Building
1114 Avenue of the Americas
32nd Floor
New York, NY 10036
Re:Global Net Lease, Inc.
PREC14A filed by Blackwells Capital LLC et al.
Filed December 1, 2022
File No. 001-37390
Dear Lawrence S. Elbaum:
            We have reviewed your filing 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 these comments by providing the requested information or advise us as
soon as possible when you will respond. If you do not believe our comments apply to your facts
and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
PREC14A filed December 1, 2022
Reasons for the Solicitation, page 5
1.Footnote 16 on page 7 appears to provide an incorrect citation.  Please revise or advise.
Proposal 1: Election of Nominees, page 8
2.The meaning of the final sentence of the third paragraph on page 8, which begins "Neither
of Mr. Lozier nor Mr. O'Toole...," is unclear.  Please revise or advise.
Proposal 2: Bylaw Repeal Proposal, page 11
3.Please disclose the text of Amendment No. 2 to the Bylaws and/or a reference to where
shareholders can find such text.

 FirstName LastNameLawrence S. Elbaum, Esq.
 Comapany NameVinson & Elkins LLP
 December 12, 2022 Page 2
 FirstName LastName
Lawrence S. Elbaum, Esq.
Vinson & Elkins LLP
December 12, 2022
Page 2
Proposal 5: Director Resignation Policy Proposal, page 14
4.We note that the resolution seeks a voting standard tied to "the affirmative vote of the
holders of a majority of the voting power of the Company’s outstanding capital stock
entitled to vote thereon."  Such standard appears to call for a majority of shares
outstanding, rather than a majority of votes cast.  Related disclosure indicates that such a
standard would be "in line with best corporate governance practices."  Please confirm that
the standard sought is in fact tied to a majority of shares outstanding, and if so, please
disclose, if true, that such a standard exceeds the majority-of-votes-cast standard more
typical of U.S. public companies.
Schedule I, page I-1
5.On page I-2, we note the reference to "Related Real Estate Fund III, L.P."  Please disclose
who this entity is and its relationship to Related Fund Management, LLC.  The phrase
"[a]s of the date of this Notice" is also unclear.  Please revise to clarify.
            We remind you that the filing persons are responsible for the accuracy and adequacy of
their disclosures, notwithstanding any review, comments, action or absence of action by the staff.
            Please direct any questions to David Plattner at 202-551-8094.
Sincerely,
Division of Corporation Finance
Office of Mergers and Acquisitions

Mail Stop 3233

January 27 , 2017

VIA E -MAIL
Mr. Nicholas Radesca
Chief Financial Officer
Global Net Lease, Inc.
405 Park Avenue, 14th Floor
New York, New York 10022

Re: Global Net Lease, Inc.
 Form 8-K dated August 8, 2016
Filed August 8, 2016
File No. 001 -37390

Dear Mr. Radesca :

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 the ir disclosure s, notwithstanding
any review, comments, action or absence  of action  by the staff .

Sincerely,

 /s/ Daniel L. Gordon

        Daniel L. Gordon
Senior Assistant Chief Accountant
Office of Real Estate and
Commodities

CORRESP
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January 26, 2017

Via EDGAR

Mr. Daniel L. Gordon

Senior Assistant Chief Accountant

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

Washington, D.C. 20549

 Re: Global Net Lease, Inc. (the “Company”)

Form 8-K dated August 8, 2016

Filed: August 8, 2016

File No. 001-37390

Dear Mr. Gordon:

Set forth below are the Company’s responses to the comments
of the Staff of the Securities and Exchange Commission (the “Commission”) contained in your letter to Timothy Salvemini
of the Company, dated January 12, 2017 (the “January 12th Letter”). For convenience of reference, the Staff comments
contained in the January 12th Letter are reprinted below in bold type and are followed by the corresponding response of the Company.

The headings and numbered paragraphs below correspond to the
headings and numbered paragraphs of the letter. References to page numbers (other than in headings taken from the September 28th
Letter) are to pages of Exhibit 99.1.

Form 8-K Filed on August 8, 2016

Exhibit 99.1

 1. We have considered your response to comment two. Given the characteristics of the adjustments made to arrive at adjusted
funds from operations (AFFO) and the correlation between the presented AFFO amounts to cash flow from operations, it appears AFFO
can be used as a liquidity measure. Pursuant to Question 102.05 of the updated Non-GAAP Compliance and Disclosure Interpretations
issued on May 17, 2016, please revise future filings to exclude presentation of AFFO on a per share basis.

In accordance with the Staff’s comment, we
confirm that the Company will exclude from future filings references to AFFO on a per share basis. We understand that we may continue
to report AFFO on an aggregate basis and may report, in close proximity, the number of shares outstanding as of an applicable date.
As our counsel from Proskauer discussed with you, however, our advisory agreement with our external advisor requires us to pay
the advisor an incentive fee. As defined in the advisory agreement, the incentive fee is equal to a percentage of “Core AFFO
Per Share” (defined in the agreement). To the extent that we pay a material amount of incentive compensation, we may be,
in disclosing the payments, required to disclose the amount of “Core AFFO Per Share” generated by the Company.

Mr. Daniel L. Gordon

Senior Assistant Chief Accountant

January 26, 2017

Page 2

We appreciate your review and assistance. Please feel free to
contact me at (212) 415-6559 should you require additional information or have any questions.

Sincerely,

/s/ Nicholas Radesca

Nicholas Radesca

Chief Financial Officer, Treasurer

and Secretary

 Cc: Michael J. Choate, Proskauer Rose LLP

Thomas Wilkin, PricewaterhouseCoopers

Mail Stop 3233

January 12, 2017

VIA E -MAIL
Mr. Timothy Salvemini
Chief Financial Officer
Global Net Lease, Inc.
405 Park Avenue, 14th Floor
New York, New York 10022

Re: Global Net Lease, Inc.
 Form 8-K dated August 8, 2016
Filed August 8, 2016
File No. 001 -37390

Dear Mr. Salvemini :

We have reviewed  your October 21, 2016  response to our comment  letter  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 comment  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you  do not believe our
comment applies  to your facts and circumstances, please tell us why in your response.

After reviewing your response to this comment , we may have additional comments.
Unless we note otherwise, our references to prior comments are to c omments in our September
28, 2016  letter .

FORM 8 -K FILED ON AUGUST 8, 2016

Exhibit 99.1

1. We have considered your response to comment two.   Given the characteristics of the
adjustments made to arrive at adjusted funds from operations (AFFO) and the correlation
between the presented  AFFO amounts to cash flow from operations, it appears AFFO can
be used as a liquidity measure.   Pursuant to Question 102.05 of the updated Non -GAAP
Compliance and Disclosure Interpre tations issued on May 17, 2016, please revise future
filings to exclude presentation of AFFO on a per share basis.

Timothy Salvemini
Global Net Lease, Inc.
January 12 , 2017
Page 2

 You may contact Wilson K. Lee at (202) 551 – 3468, Lyn Shenk at (202) 551 – 3380, or
me at (202) 551 - 3486 with any questions.

Sincerely,

 /s/ Daniel L. Gordon

        Daniel L. Gordon
Senior Assistant Chief Accountant
Office of Real Estate and
Commodities

CORRESP
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November 4, 2016

Via EDGAR

Mr. Coy Garrison

Special Counsel

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

Washington, D.C. 20549

 Re: Global Net Lease, Inc.

Registration Statement on Form
S-4

Filed September 19, 2016

File No. 333-213691

Dear Mr. Garrison:

We are transmitting for filing the Company’s response
to the verbal comments of the Staff (the “Staff”) of the Securities and Exchange Commission (the “Commission”)
as we discussed on November 3, 2016 (the “November 3rd Conversation”) regarding the joint proxy statement/registration
statement on Form S-4 (the “Form S-4”) filed by Global Net Lease, Inc. (“GNL”) and American Realty Capital
Global Trust II, Inc. (“Global II,” and together with GNL, the “Companies”). References to page numbers
are to pages of the Form S-4.

Proposed change to “Potential Conflicts”

We advise the Staff that the disclosure on pages 17 and 110
has been revised as follows:

In connection with the merger agreement, 90 Global II OP
Units and 8,888 shares of Global II common stock held by the Global II Advisor and its affiliates will
be exchanged for an aggregate of 204 20,380 shares
of GNL common stock and 125,020 Class B Units held by the Global II Advisor and its other service providers will vest and will
be exchanged for 283,795 shares of GNL common stock. In addition, 6,932 unvested restricted shares of common stock held by independent
directors of Global II will vest and will be exchanged for 15,735 shares of GNL common stock.

Response to reorganization opinion comment

In response to the Staff’s verbal comment, the issuer
confirms that the conditions of Staff Legal Bulletin 19 for not filing the opinion of counsel regarding the treatment of the merger
as a tax-free reorganization prior to effectiveness are met and that the final opinion of counsel regarding the treatment of the
merger as a tax-free reorganization will be filed in a post-effective amendment by the closing date of the merger.

Coy Garrison

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

November 4, 2016

Page 2

We appreciate your review and assistance. Please feel free to
contact me at (917) 475-2216 should you require additional information or have any questions.

    Sincerely,

    /s/ Scott J. Bowman

    Scott J. Bowman

    Chief Executive Officer

cc: Michael J. Choate, Esq. Proskauer Rose LLP

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November 7, 2016

VIA EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attention: Coy Garrison

 Re: Global Net Lease, Inc.

Registration
Statement on Form S-4

Filed September 19, 2016

File No. 333-213691

Dear Mr. Garrison:

Pursuant to Rule 461 promulgated under the
Securities Act of 1933, as amended, Global Net Lease, Inc. (the “Company”) hereby requests acceleration of the effective
date of the above-referenced Registration Statement, so that it may become effective at 4:00 p.m. Eastern Time on November 8, 2016,
or as soon thereafter as practicable.

Should you have any questions, please contact
Michael J. Choate of Proskauer Rose LLP at (312) 962-3567.

[SIGNATURE
PAGE FOLLOWS]

    Respectfully submitted,

    Global Net Lease, Inc.

    By:
    /s/ Scott J. Bowman

    Name:
    Scott J. Bowman

    Title:
    Chief Executive Officer, President

CORRESP
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October 21, 2016

Via EDGAR

Mr. Coy Garrison

Special Counsel

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

Washington, D.C. 20549

 Re: Global Net Lease, Inc.

Registration Statement on Form
S-4

Filed September 19, 2016

File No. 333-213691

Dear Mr. Garrison:

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

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

General

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

Coy Garrison

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

October 21, 2016

Page 2

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

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

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

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

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

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

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

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

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

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

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

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

Coy Garrison

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

October 21, 2016

Page 3

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

No Affiliates of Global II are Engaged in the Merger Transaction

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

GNL and Global II are not affiliates

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

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

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

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

Coy Garrison

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

October 21, 2016

Page 4

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

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

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

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

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

Mail Stop 3233
October 1 7, 2016

Via E -Mail
Scott J. Bowman
Chief Executive Officer
Global Net Lease, Inc.
405 Park Avenue, 14th Floor
New York, New York 10022

Re: Global Net Lease, Inc.
  Registration Statement on Form S-4
Filed  September 19, 2016
  File No.  333-213691

Dear Mr. Bowman :

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 com ments 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, w e may have  additional comments.

General

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

Scott J. Bowman
Global Net Lease, Inc.
October 1 7, 2016
Page 2

2. We note your disclosure on pages 79 -84 that UBS presented different versions of a
“related party analysis” to the GNL Special Committee.  Please provide us  with copies  of
these materials.

The Merger

Background of the Merger, page 71

3. We note your disclosure on page 74 that the Global II Special Committee discussed with
BMO strategic alternatives other than the merger with GNL, including the prospects of
continuing as a stand -alone entity and alternative transactions involving other  potential
acquirers.  Please provide additional disclosure regarding the strategic alternatives that
were considered and why the merger was pursued instead of such alternatives.

Opinion of the GNL Special Committee’s Financial Advisor

Discounted Cash Flow Analyses, page 96

4. We note the reference to financial forecasts and estimates relating to the pro forma
combined company prepared by GNL Management .  Please revise the disclosure in your
registration statement to provide additional disclosure abo ut these financial forecasts and
estimates.

Miscellaneous, page 97

5. We note your disclosure that GNL agreed to pay UBS an aggregate fee of $4.0 million
for its financial advisory services in connection with the mergers, a portion of which was
payable in  connection with the delivery of UBS’ opinion and the remainder of which is
contingent upon consummation of the merger.   Please revise your disclosure to state what
portion of the $4.0 million fee is contingent upon consummation of the merger.

6. We note that your disclosure regarding the material relationships between UBS  and GNL
does not provide a narrative and quantitative description of the fees paid or to be paid to
UBS  and its affiliates by GNL  and it s affiliates.  Please revise to provide such disclosu res
or provide us with an analysis as to why such disclosure is not required .

Scott J. Bowman
Global Net Lease, Inc.
October 1 7, 2016
Page 3

 Opinion of the Global II Special Committee’s Financial Advisor

Miscellaneous , page 105

7. We note that your disclosure regarding the material relationships between BMO  and
Global  II does not provide a narrative and quantitative description of the fees paid or to
be paid to BMO  and its affiliates by Global II  and it s affiliates.  Please revise to provide
such disclosures  or provide us with an analysis as to why such disclosure is no t required.

Notes To Unaudited Pro Forma Consolidated Financial Statements

Note 2. Adjustments to Unaudited Pro Forma Consolidated Balance Sheet, pages F -1-10 to F -1-
11

8. We note your adjustment disclosures include a discussion related to customer relationship
intangible assets.  Based on the purchase price allocation table included on page F -1-9, it
is not clear that any adjustment amount relates to customer relationship i ntangible assets.
Please advise.

Note 3. Adjustments to Unaudited Pro Forma Consolidated Statements of Operations, page F -1-
15

9. Please tell us why adjustment (GG) to eliminate merger transaction costs has resulted in a
negative expense total for the six months ended June 30, 2016.

Annex C – Opinion of the Global II Special Committee’s Financial Advisor , page C -1

10. We note the limitation on reliance by shareholders in the fourth full paragraph on page C -
3 of the opinion, which states that BMO’s opinion has  been “ prepared at the request of
the Special Committee and is solely  for the benefit and use of the Special Committee and
the Board of Directors of the Company in the evaluation of the fairness, from a financial
point of view, to Global II’s common stockh olders of the Exchange Ratio .”  (Emphasis
added)  Because it is inconsistent with the disclosures relating to the opinion, the
limitation should be deleted.  Alternatively, disclose the basis for BMO’s belief that
shareholders cannot rely upon the opinion to support any claims against BMO arising
under applicable state law (e.g., the inclusion of an express disclaimer in BMO’s
engagement letter with Global II).  Describe any applicable state -law authority regarding
the availability of such a potential defen se.  In the absence of applicable state -law
authority, disclose that the availability of such a defense will be resolved by a court of
competent jurisdiction.  Also disclose that resolution of the question of the availability of
such a defense will have no  effect on the rights and responsibilities of the board of
directors under applicable state law.  Further disclose that the availability of such a state -
law defense to BMO would have no effect on the rights and responsibilities of either
BMO or the board o f directors under the federal securities laws.

Scott J. Bowman
Global Net Lease, Inc.
October 1 7, 2016
Page 4

Exhibit Index, page II -6

11. We note on page B -3 that UBS Securities LLC, in delivering its fairness opinion,
assumed that the transaction will not adversely affect your status or operations as a real
estate i nvestment trust for U.S. federal income tax purposes.  Please confirm that you will
file an opinion of counsel regarding your qualification as a real estate investment trust for
U.S. federal income tax purposes or provide us with a detailed analysis as to why such
opinion is not required.  Please see Item 601(b)(8) of Regulation S -K and Staff Legal
Bulletin No. 19.

We remind you that the company and its management are responsible for the accuracy
and adequacy of their disclosures, notwithstanding any rev iew, 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.

You may contact Howard Efron, Staff Accountant, at (202) 551 -3439 or Robert
Telewicz, Branch Chief, at (202) 551 -3438 if you have questions regarding comments on the
financial statements and related matters. Please contact Bryan Hough, Staff Attorney, at  (202)
551-8625  or me at (202) 551 -3466  with any other questions.

Sincerely,

 /s/ Coy Garrison

Coy Garrison
Special Counsel
Office of Real Estate and
Commodities

cc:  Michael J. Choate, Esq.  (Via E -Mail)
 Proskauer Rose LLP

CORRESP
1
filename1.htm

October 7, 2016

Via EDGAR

Mr. Daniel L. Gordon

Senior Assistant Chief Accountant

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

Washington, D.C. 20549

 Re: Global Net Lease, Inc. (the “Company”)

Form
8-K dated August 8, 2016

Filed:
August 8, 2016

File
No. 001-37390

Dear Mr. Gordon:

Set forth below are the Company’s responses to the comments
of the Staff of the Securities and Exchange Commission (the “Commission”) contained in your letter to Timothy Salvemini
of the Company, dated September 28, 2016 (the “September 28th Letter”). For convenience of reference, the
Staff comments contained in the September 28th Letter are reprinted below in bold type and are followed by the corresponding
response of the Company.

The headings and numbered paragraphs below correspond to the
headings and numbered paragraphs of the letter. References to page numbers (other than in headings taken from the September 28th
Letter) are to pages of Exhibit 99.1.

Form 8-K Filed on August 8, 2016

Exhibit 99.1

 1. Please explain to us the rationale for adjusting for unrealized gains and losses on foreign currency transactions in arriving
at AFFO.

The Company invests in real estate properties in foreign countries
and as a result, exposes the rental income, property related expenses and interest expense associated with these properties to
fluctuations in foreign exchange rates. The Company utilizes foreign currency derivatives, including currency forward contracts
and cross currency swap agreements, to manage this exposure. These derivative contracts are not designated as hedges under qualifying
hedge relationships, and as a result, changes in the fair value relating to future contractual settlements along with current
contractual settlements relating to current period operations are recorded directly to net income (loss).

Mr. Daniel L. Gordon

Senior Assistant Chief Accountant

October 7, 2016

Page 2

The Company adjusts AFFO to eliminate the impact of the
unrealized changes in fair value of these foreign currency derivative contracts as the unrealized mark to market adjustment
on the unsettled derivative contracts relates to currency exposure on future period operations that may or may not be
ultimately realized in future periods. Accordingly, we believe that the unrealized mark to market adjustment on such
contracts are not a measure of our operating performance and should be excluded in determining AFFO. The Company believes the
performance of these derivative contracts occurs upon the settlement of such contracts, which reflects the direct impact on
earnings related to the aforementioned revenue and expenses associated with these investments, and accordingly, are included
for AFFO purposes.

 2. On page 12 you explain that excluding non-cash income and expense items from AFFO provides useful information regarding
income and expense items which have no cash impact and do not provide liquidity to the company or require capital resources of
the company. This strongly implies that AFFO is a liquidity measure. Please explain to us why you believe it is appropriate to
present this measure on a per share basis. See Question 102.05 of the updated Non-GAAP Compliance and Disclosure Interpretations
issued May 17, 2016.

We acknowledge the Staff’s comment. Our overall explanation
of the reasons for using AFFO focused on our view that AFFO is an important measure of the Company’s operating performance
that assists investors in assessing the sustainability of our ongoing operating performance. The language referred to by the Staff
that could imply that AFFO is also a liquidity measure should not have been included as part of the description of AFFO, as the
Company does not use AFFO as a liquidity measure. Accordingly, in the future, the Company proposes to use the following language
to describe AFFO, which eliminates the references to “no cash impact and do not provide liquidity to the company or require
capital resources of the company” and “cash flows impact the liquidity and capital resources available to distribute
to investors”:

We exclude certain income or expense items from AFFO
that we consider more reflective of investing activities, other non-cash income and expense items and the income and expense effects
of other activities that are not a fundamental attribute of our business plan. These items include early extinguishment of debt
and unrealized gains and losses, which may not ultimately be realized, such as gains or losses on derivative instruments, gains
and losses on foreign currency transactions, and gains and losses on investments. In addition, by excluding non-cash income and
expense items such as amortization of above-market and below-market leases intangibles, amortization of deferred financing costs,
straight-line rent and equity-based compensation from AFFO, we believe we provide useful information regarding income and expense
items which have a direct impact on our ongoing operating performance. We also include the realized gains or losses on foreign
currency exchange contracts for AFFO as such items are part of our ongoing operations and affect the current operating performance
of the Company. By providing AFFO, we believe we are presenting useful information that assists investors and analysts to better
assess the sustainability of our ongoing operating performance without the impacts of transactions that are not related to the
ongoing profitability of our portfolio of properties. We also believe that AFFO is a recognized measure of sustainable operating
performance by the REIT industry. Further, we believe AFFO is useful in comparing the sustainability of our operating performance
with the sustainability of the operating performance of other real estate companies. However, AFFO is not indicative of cash available
to fund ongoing cash needs, including the ability to make cash distributions. Investors are cautioned that AFFO should only be
used to assess the sustainability of our operating performance excluding these activities, as it excludes certain costs that have
a negative effect on our operating performance during the periods in which these costs are incurred.

Mr. Daniel L. Gordon

Senior Assistant Chief Accountant

October 7, 2016

Page 3

In calculating AFFO, we exclude certain expenses,
which under GAAP are characterized as operating expenses in determining operating net income. All paid and accrued merger, acquisition
and transaction related fees and certain other expenses negatively impact our operating performance during the period in which
expenses are incurred or properties are acquired will also have negative effects on returns to investors, but are not reflective
of our on-going performance. AFFO that excludes such costs and expenses would only be comparable to companies that did not have
such activities. Further, under GAAP, certain contemplated non-cash fair value and other non-cash adjustments are considered operating
non-cash adjustments to net income. In addition, as discussed above, we view gains and losses from fair value adjustments as items
which are unrealized and may not ultimately be realized and not reflective of ongoing operations and are therefore typically adjusted
for when assessing operating performance. Excluding income and expense items detailed above from our calculation of AFFO provides
information consistent with management's analysis of the operating performance of the Company. Additionally, fair value adjustments,
which are based on the impact of current market fluctuations and underlying assessments of general market conditions, but can also
result from operational factors such as rental and occupancy rates, may not be directly related or attributable to our current
operating performance. By excluding such changes that may reflect anticipated and unrealized gains or losses, we believe AFFO provides
useful supplemental information.

 3. In your next earnings release, please provide a substantive and concise discussion of why Cash NOI is useful to investors.
Please provide us with your proposed changes in your response letter.

We propose adding the following definition to materials in which
we use Cash NOI:

Cash net operating income, or Cash NOI, is a non-GAAP financial
measure that is intended to reflect the performance of our properties. We define Cash NOI as net operating income (which
is separately defined herein) excluding amortization of above/below market lease intangibles and straight-line adjustments that
are included in GAAP lease revenues. We believe that Cash NOI is a helpful measure that both investors and management can use to
evaluate the current financial performance of our properties and it allows for comparison of our operating performance between
periods and to other REITs. Cash NOI should not be considered as an alternative to net income, as an indication of our financial
performance, or to cash flows as a measure of liquidity or our ability to fund all needs. The method by which we calculate and
present Cash NOI may not be directly comparable to the way other REITs present Cash NOI.

*************

Mr. Daniel L. Gordon

Senior Assistant Chief Accountant

October 7, 2016

Page 4

In connection with the Company’s response to the September
28th Letter, the Company acknowledges 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

 · It 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 appreciate your review and assistance. Please feel free to
contact me at (917) 475-2182 should you require additional information or have any questions.

Sincerely,

/s/ Timothy Salvemini

Timothy Salvemini

Chief Financial Officer

 Cc: Michael J. Choate, Proskauer Rose LLP

Thomas
Wilkin, PricewaterhouseCoopers

Mail Stop 3233

September 28, 2016

VIA E -MAIL
Mr. Timothy Salvemini
Chief Financial Officer
Global Net Lease, Inc.
405 Park Avenue, 14th Floor
New York, New York 10022

Re: Global Net  Lease, Inc.
 Form 8-K dated August 8, 2016
Filed August 8, 2016
File No. 001 -37390

Dear Mr. Salvemini :

We have limited our review of your filing 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 these comments  within ten busine ss days by providing the requested
information or advis e us as soon as possible when you will respond.  If you do not believe our
comments apply to your facts and circumstances, please tell us why in your response.

After reviewing your response to these  comments, we may have  additional comments.

FORM 8 -K FILE D ON AUGUST 8, 2016

Exhibit 99.1

1. Please explain to us the rationale for adjusting for unrealized gains and losses on foreign
currency transactions in arriving at AFFO.

Timothy Salvemini
 Global Net Lease, Inc.
 September 28, 201 6
 Page 2

 2. On page 12 you explain that excluding non -cash income and expense items from AFFO
provides useful information regarding income and expense items which have no cash
impact and do not provide liquidity to the company or require capital resources of the
company.  This strongly implies that AFFO is a liquidity measure.  Please explain to us
why you believe it is appropriate to present this measure on a per share basis.  See
Question 102.05 of the updated Non-GAAP Compliance and Disclosure Interpretations
issued on  May 17, 2016.

3. In your next earnings release, please provide a substantive  and concise  discussion of why
Cash NOI  is useful to investors.  Please provide us with your proposed changes in your
response letter .

We urge all persons who are responsible for t he 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 al l 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 as sert 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 Wilson K. Lee at (202) 551 – 3468, Lyn Shenk at (202) 551 – 3380, or
me at (202) 551 - 3486 with any questions.

Sincerely,

 /s/ Daniel L. Gordon

        Daniel L. Gordon
Senior Assistant Chief Accountant
Office of Real Estate and
Commodities

Mail Stop 3233

July 11, 201 6

Via E -mail
Mr. Timothy Salvemini
Chief Financial Officer
Global Net Lease, Inc.
405 Park Ave., 14th Floor
New York , NY  10022

Re:  Global Net Lease, Inc.
 Form 10-K for the  fiscal  year ended December  31, 2015
Filed February  29, 201 6
File No. 1-37390

Dear Mr. Salvemini :

 We have completed our review of your filing.  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 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 la ws of the United States.  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 rules require.

Sincerely,

        /s/ Jennifer Monick

Jennifer Monick
Assistant Chief Accountant
Office of Real Estate & -
    Commodities

CORRESP
1
filename1.htm

July 7, 2016

Via EDGAR

Ms. Jennifer Monick

Assistant Chief Accountant

Office of Real Estate & Commodities

U.S. Securities and Exchange Commission

Washington, D.C. 20549

 Re: Global Net Lease, Inc. (the “Company”)

Form 10-K for the year ended December
31, 2015

Filed: February 29, 2016

File No. 1-37390

Dear Ms. Monick:

We are transmitting for filing the Company’s response
to the comments of the Staff of the Securities and Exchange Commission (the “Commission”) contained in your letter
to Timothy Salvemini of the Company, dated June 24, 2016 (the “June 24th Letter”). For convenience of reference,
the Staff comments contained in the June 24th Letter are reprinted below in bold type and are followed by the corresponding
response of the Company.

The headings and numbered paragraphs below correspond to the
headings and numbered paragraphs of the letter. References to page numbers (other than in headings taken from the June 24th
Letter) are to pages of the Form 10-K.

Form 10-K for the fiscal year ended December 31, 2015

Financial Statements

Note 8 – Derivatives and Hedging Activities, Page
F-27

 1. We note that you have recorded $5.1 million of hedge ineffectiveness in earnings during 2015. Please tell us how you considered
the hedge ineffectiveness in your determination that your hedges are highly effective. Within your response, please reference the
authoritative accounting literature management relied upon.

The Company has investments in consolidated entities whose functional
currencies are British Pound Sterling (“GBP”) and Euro (“EUR”), which differs from that of the Company
which is the US Dollar (“USD”). As part of its risk management program, the Company uses non-derivative financial instruments
to hedge its exposure to both GBP-USD and EUR-USD exchange rates. These non-derivative financial instruments have generally included
GBP and EUR denominated debt (foreign currency denominated draws on our line of credit) issued and outstanding with third parties
(the “Hedging Instruments”) to protect the value of its net investments in GBP and EUR subsidiaries against changes
in the GBP-USD and EUR-USD exchange rates.

Ms. Jennifer Monick

Assistant Chief Accountant

July 7, 2016

Page 2

Using the strategy described above (as documented in our hedge
memos), on the designation date and at the beginning of each quarterly period thereafter, the entire notional amount of each Hedging
Instrument is designated against a corresponding amount of the Company’s GBP and EUR subsidiaries’ net investment balances
until the entire notional amount of each Hedging Instrument has been designated. If the Company’s net investment balance
is greater than the total notional amount of Hedging Instruments designated as net investment hedges, then the entire notional
amount of the designated Hedging Instruments will continue to be accounted for as net investment hedges. In the event the total
net investment balance in each currency is less than the total amount drawn on the Hedging Instruments in each currency designated
herein, the excess portion of the Hedging Instruments are de-designated. For any amounts drawn but not designated as Hedging Instruments,
the notional amount is re-measured each reporting period with any related re-measurement gains/losses recognized in the Company’s
current period earnings in accordance with ASC 830.

Accordingly, pursuant to paragraphs 815-35-35-12 to 815-35-35-15,
there will be no ineffectiveness recognized in earnings if the notional amount of the designated portion of the Hedging Instruments
(in whole or in part) matches the respective net investment balance designated as hedged items and the Hedging Instruments are
denominated in the functional currency of the net investment (i.e., GBP and EUR).

The Company’s disclosure on Page F-30 was intended to
disclose that there was an excess/undesignated portion of the foreign draws but was inconsistent with our hedge documentation.
While the total amounts reflected in the income statement were correct and the amounts of the excess foreign draws were disclosed
properly (Page F-30), the Company’s income statement caption for these and the related disclosure indicated that the whole
amounts of foreign draws were so designated and the income statement impact was for ineffectiveness in a hedge relationship rather
than for impact of currency exchange rates on the undesignated portions of these excess foreign currency draws. The Company will
clarify this in future filings.

In connection with the Company’s response to the June
24th Letter, the Company acknowledges 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

 · It 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 appreciate your review and assistance. Please feel free to
contact me at (917) 475-2182 should you require additional information or have any questions.

Sincerely,

/s/ Timothy Salvemini

Timothy Salvemini

Chief Financial Officer

 Cc: Michael J. Choate, Proskauer Rose LLP

Thomas Wilkin, PricewaterhouseCoopers

Mail Stop 3233

June 24, 201 6

Via E -mail
Mr. Timothy Salvemini
Chief Financial Officer
Global Net Lease, Inc.
405 Park Ave., 14th Floor
New York , NY  10022

Re:  Global Net Lease, Inc.
 Form 10-K for the  fiscal  year ended December  31, 2015
Filed February  29, 201 6
File No. 1-37390

Dear Mr. Salvemini :

 We have limited our review of your filing to the financial statements and related disclosures
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 our comment within ten business days by providing the requested
information or advise us as soon as possible when you will respond.  If you do not believe our
comment appl ies to your facts and circumstances, please tell us why in your response.

After reviewing your response to this comment, we may have additional comments.

Form 10 -K for the fiscal year ended December 31, 201 5

Financial Statements

Note 8 – Derivatives and Hedging Activities, page F -27

1. We note you have recorded $5.1 million of hedge ineffectiveness in earnings during
2015.  Please tell us how you considered the hedge  ineffectiveness in your determination
that your hedges are highly effective.  Within your response, please reference the
authoritative accounting literature management relied upon.

Timothy Salvemini
 Global Net Lease,  Inc.
 June 24, 201 6
 Page 2

 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 compa ny 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, please provide a written statement from the com pany
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 t o 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 Howard Efron, Staff Accountant, at (202) 551 -3439  or me at (202) 551 -
3295 if you have questions regarding comments on the financial statements and related matters.

Sincerely,

        /s/ Jennifer Monick

Jennifer Monick
Assistant Chief Accountant
Office of Real Estate & -
    Commodities

CORRESP
1
filename1.htm

June 18, 2015

Via EDGAR

Ms. Christina Chalk

Senior Special Counsel

Office of Mergers and Acquisitions

U.S. Securities and Exchange Commission

Washington, D.C. 20549

 Re: Global Net Lease, Inc.

Schedule TO-I

Filed June 2, 2015

File No. 005-88785

Dear Ms. Chalk:

I am writing in response to your letter, dated June 8, 2015,
regarding the comments of the Staff of the Office of Mergers and Acquisitions (the “Staff”) of the Securities
and Exchange Commission (the “Commission”) pertaining to the Schedule TO of the above referenced company (the
“Company”). The Staff’s comments, as included in that letter, are repeated below in bold type, followed
by the Company’s responses. Concurrently with the filing of this letter, the Company filed Amendment No. 1 to the Schedule
TO, which includes an amendment to the Offer to Purchase (the “Amendment to the Offer to Purchase”), filed as
exhibit (a)(xviii) to the Schedule TO, that reflects changes in response to the Staff’s comments.

Exhibit (a)(i) - Offer to Purchase

Withdrawal Rights, page 4

 1. We believe the reference to June 29, 2015 as the date by which “back end withdrawal rights” arise may be a typographical
error. Please revise consistent with the requirements of Rule 13e-4(f)(2)(ii).

The Company acknowledges the Staff’s comment. Please see
the Amendment to the Offer to Purchase, which corrects the deadline date for withdrawal.

Christina Chalk

Senior Special Counsel

June 18, 2015

Page 2

Conditions of the Offer, page 21

 2. Refer to the disclosure on page 24 in this section. Provide additional details such that shareholders can understand the
parameters of the “REIT condition” referenced here. For example, explain what may cause you to fail to qualify for
taxation as a REIT under the Code, such that you would not be obligated to complete the Offer.

  The Company believes that this condition is typical for tender offers by REIT’s, and the Company does not believe that its tender offer poses any unique risks to its REIT qualification. Nevertheless, the Company has revised the disclosure to clarify that, under applicable federal income tax law, the Company could fail to qualify for taxation as a REIT under the Code if certain stockholder ownership requirements were violated or the tender offer resulted in a preferential dividend.

The Company must distribute annually to its stockholders
at least 90% of its REIT taxable income (which does not equal net income as calculated in accordance with generally accepted
accounting principles in the United States of America), determined without regard to the deduction for dividends paid and
excluding net capital gain. In order for distributions to be counted as satisfying the annual distribution requirements for
REITs, and to provide the Company with a REIT-level tax deduction, the distributions must not be “preferential
dividends.” A dividend is not a preferential dividend if the distribution is pro rata among all outstanding shares of
stock within a particular class, and in accordance with the preferences among different classes of stock as set forth in the
Company’s organizational documents. If the receipt of cash by a stockholder in exchange for shares pursuant to the
Offer is treated as a distribution to the stockholder with respect to the stockholder’s shares, see Section 14 of the
Offer to Purchase, such distribution will be treated as ordinary dividend income to the stockholder to the extent of such
stockholder’s ratable share of the Company’s current and accumulated earnings and profits (to the extent not
designated as capital gain dividends or qualified dividend income) as determined under U.S. federal income tax principles and
would likely be treated as a preferential dividend and not count toward the Company meeting the annual
distribution requirement. Such preferential dividend could taint a regular dividend distribution by the Company, if the
Internal Revenue Service were to treat the payment of cash by the Company to tendering stockholders as part of a regular
dividend distribution by the Company, which could impact its ability to qualify as a REIT. The Company intends to separate
the payment to tendering shareholders and its next regular dividend distribution so as to minimize any risk of there being a
preferential dividend issue with its regularly scheduled dividend distribution.

Christina Chalk

Senior Special Counsel

June 18, 2015

Page 3

Source and Amount of Funds, page 25

 3. We note that the Offer is conditioned on the Credit Facility Condition being satisfied. In this section, you state that
you expect to use cash totaling approximately $25 million and expect to borrow about $100 million under the Company’s existing
revolving loan Credit Facility. On page 26 of the Offer to Purchase, you state that available borrowings under the Credit Facility
are based on a pool of eligible unencumbered real estate assets and that the unused borrowing capacity as of March 31, 2015 was
$71.6 million. Please advise how you will borrow the necessary $100 million needed to fund the Offer. We may have additional comments.

We have updated the disclosure regarding the Company’s
Credit Facility. This updated disclosure addresses the Staff’s comments. On June 16, 2015 we completed $46.9 million in
mortgage financings with respect to certain European properties, the proceeds of which are being used to reduce our outstanding
balance under our Credit Facility.

Miscellaneous

 4. We note the disclosure here that the Offer is “neither being made to, not will tenders be accepted from or on behalf
of, stockholders in any jurisdiction in which the making of the Offer or acceptance thereof would not be in compliance with the
laws of such jurisdiction.” Please note that the all-holders provision in Exchange Act Rule 13e-4(f)(8) applies equally to
U.S. holders as well as non-U.S. holders. Refer to the interpretive guidance in section II.G.1 of SEC Release 33-8957. While an
offer need not be made into certain countries where doing so would be illegal, you may not refuse to accept tenders from holders
in certain jurisdictions. Please revise or advise.

In response to the Staff’s comment, the Company advises
the Staff that it is referring only to excluding stockholders located in a U.S. state pursuant to Rule 13e-4(f)(9)(ii) of the Securities
Exchange Act of 1934, as amended.  The Company has revised the disclosure in accordance with the Staff’s comment.
Please see the Amendment to the Offer to Purchase.

The Company acknowledges that:

 · It is responsible for the adequacy and accuracy of the disclosure in the filing;

Christina Chalk

Senior Special Counsel

June 18, 2015

Page 4

 · 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

 · It 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 the Company’s counsel, Michael J. Choate
at (312) 962-3567 if you have any questions regarding the foregoing.  Also, please advise whether the Staff has any additional
comments to the Schedule TO.

    Very truly yours,

    GLOBAL NET LEASE, INC.

    By:
    /s/ Scott J. Bowman

    Scott J. Bowman

    Chief Executive Officer

    cc:
    James A. Tanaka, RCS Capital Corporation

    Michael J. Choate, Proskauer Rose LLP

June 8 , 2015

Via E -Mail
Michael Choate
Proskauer Rose  LLP
Three First National P laza
Chicago, IL 60602 -4242

Re: Global Net Lease, Inc .
Schedule TO-I filed June  2, 2015
File No.  5-88785

Dear Mr. Choate :

The staff in the Office of Mergers and Acquisitions in the Division of Corporation
Finance has conducted a limited review of the above filing concerning the matters identified in
our comment s below. U nless otherwise noted, all defined terms used in this letter have t he same
meaning as in your offer materials.

Please respond to this letter by amendi ng your filing . If you do not believe our comment s
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 th ese comment s, we may have additional comments .

Exhibit (a)(i)  - Offer to Purchase

Withdrawal Rights , page 4

1. We believe the reference to June 29, 2015 as the date by which “back end withdrawa l
rights ” arise may be a typographical error. Please revise consistent with the
requirements of Rule 13e -4(f)(2)(ii).

Conditions of the Offer, page 21

2. Refer to the disclosure  on page 24 in this section. Provide additional details such that
shareholders can understand  the parameters of the “REIT condition ” referenced here.
For example, explain what may cause you to fail to qualify for taxation as a REIT
under the Code, such that you would not be obligated to complete the Offer.

Michael Choate , Esq.
Proskauer Rose  LLP
June 8 , 2015
Page 2

 Source and Amount of Funds, page 25

3. We note that the Offer is conditione d on the Credit Facility Condition being satisfied.
In this section, you state that you expect to use cash totaling  approximately $25
million and expect to borrow about $100 million  under the Company ’s existing
revolving l oan Credit Facility.  On page 26 of the Offer to Purchase, you state that
available borrowings u nder the Credit Facility are based on a pool of eligi ble
unencumbered real estate assets and that the unused borrowing capacity as of March
31, 2015 was $71.6 million. Please advise  how you will  borrow the necessary $100
million needed to fund the Offer. We may have additional comments.

Miscellaneous

4. We note the disclosure  here that the Offer is “neither  being made to, not will tender s
be accepted  from or on behalf of, stockholders in any jurisdiction in which the
making of the Offer or acceptance thereof would not be in compliance  with the laws
of such jurisdiction .” Please note that the all -holders provision in Exchange Act Rule
13e-4(f)(8) applies equally to U.S. holders as well as non -U.S. holders. Refer to the
interpre tive guidance in section II.G.1  of SEC Release 33 -8957. While an offer need
not be made into certain countries where doing so would be illegal , you may not
refuse to accept tenders f rom holders in certain jurisdictions. Please revise or advise.

Closing  Information

Please amend  the filing  in respons e to the above  comment.  We may have further
comments upon receipt of your additional filing(s) ; therefore, please allow adequate time for
further staff review.

You should furnish a response letter with the amendment keying your responses to our
comment letter  and providing any supplemental information we have requested.  Please
transmit the letter via EDGAR under the label “CORRESP.”  In the event that you believe
that compliance with the above comment 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 reviewed by the staff to be certain that they have provided all information
investors require for an informed decision.  Sin ce the Company is in possession of all facts
relating to its disclosure, 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:

 It is responsible for the adequacy and accuracy of the disclosure in the filing;

Michael Choate , Esq.
Proskauer Rose  LLP
June 8 , 2015
Page 3

 staff comments or changes to disclosure in response to staff comments do not foreclose
the Commission from taking any action with respe ct 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 direct any questions about th is comment or your filing to me at 202 -551-3263.

Sincerely,

/s/ Christina Chalk

Christina Chalk
Senior Special Counsel
Office of Mergers and Acquisitions

January  21, 201 5

Via E -mail
Mr. Patrick Goulding
Chief Financial Officer
American Realty Capital Global Trust, Inc.
405 Park Avenue , 14th Floor
New York , NY  10022

Re: American Realty Capital Global Trust, Inc.
 Form 10-K for the  fiscal  year ended December  31, 2013
Filed March  7, 201 4
File No. 0-55202

Dear Mr. Goulding :

We have completed our review of your filing.  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 and the company may not assert staff
comments as a defense in any proceeding initiated by the Commission or any person under the
feder al securities laws of the United States.  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 ru les require.

Sincerely,

        /s/ Kevin Woody

Kevin Woody
Branch Chief

CORRESP
1
filename1.htm

Proskauer Rose LLP Eleven Times Square New York, NY 10036-8299

December 31, 2014

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Mr. Kevin Woody

    Re:
    American Realty Capital Global Trust Inc.

    Form 10-K for the fiscal year ended December 31, 2013

    Filed March 7, 2014

    File No. 0-55202

Dear Mr. Woody:

On behalf of our client,
American Realty Capital Global Trust Inc. (the “Company”), we are submitting this letter in response to the
comments of the staff (the “Staff”) of the United States Securities and Exchange Commission (the “Commission”)
set forth in the Staff’s letter dated December 15, 2014 (the “Amendment”) to the Annual Report on Form
10-K filed by the Company with the Commission on March 7, 2014 (the “10-K”).

Responses to the comments
have been provided by the Company to us and are set forth below.

Item 1. Business, page 5

 1. We
note that you invest in net leases and that you consider tenant creditworthiness in your evaluation of investment opportunities.
In future filings, please also include a discussion of how management monitors the tenant credit quality of its current portfolio.

The Company advises the Staff that it will
include the requested disclosure in future filings.

Notes to Consolidated Financial Statements

Note 2 – Summary of Significant Accounting Policies

Real Estate Investments, page F-9

 2. Please
tell us and disclose your policy for determining whether the acquisition of real estate is a business or asset purchase and the
result of that determination on how your record the cost of the transaction. Please ensure you address sale/leaseback transactions
in your disclosure.

The Company reviews the provisions of FASB
Accounting Standards Codification Topic 805 on Business Combinations (“Topic 805") to determine whether an acquisition
should be treated as a business combination or an asset acquisition and applies the definition of the term "business"
and related guidance set forth in Topic 805 to the transaction. If the assets acquired meet the definition of a business under
Topic 805, thereby making the acquisition a business combination, the Company applies the acquisition method for a business combination
as provided for in Topic 805; otherwise, the Company accounts for the transaction as an asset acquisition.

Topic 805 defines the term "business"
as "[a]n integrated set of activities and assets that is capable of being conducted and managed for the purpose of providing
a return in the form of dividends, lower costs, or other economic benefits directly to investors or other owners, members, or participants."
Topic 805 sets forth additional guidance on what constitutes a business and provides that a business is comprised of three elements:
input; process; and output. Topic 805 defines the first element, input, as "[a]ny economic resource that creates, or has the
ability to create, outputs when one or more processes are applied to it." Topic 805 defines the second element, process, as
"[a]ny system, standard, protocol, convention, or rule that when applied to an input or inputs, creates or has the ability
to create outputs." Topic 805 provides examples of what constitutes a process, which include "strategic management processes,
operational processes, and resource management processes," but which typically exclude "[a]ccounting, billing, payroll,
and other administrative systems." With respect to the third element, output, Topic 805 provides that outputs are created
by the combination of the first two elements (i.e., inputs and processes applied to those inputs), but are not required for an
integrated set to qualify as a business.

In conducting an analysis of the application
of Topic 805, the Company reviews the detailed definitions of inputs, processes and outputs for each acquisition. The Company generally
acquires single occupancy, special purpose properties that are leased, or, in the case of sale/lease back transactions, will be
leased concurrently with the acquisition, under long-term triple-net leases. Accordingly, the Company believes that the first element
necessary to qualify as a business under Topic 805, input, is satisfied in that the acquisition of its properties represents the
inputs necessary for the Company to implement its business plan to operate as a lessor of real estate . The Company has generally
concluded that its acquisitions of net lease properties, including acquisitions through sale/leaseback transactions, have involved
a “process” component because the Company has the capability and intent to operate, or engage a third-party to operate,
property management, maintenance, security and other functions at the acquired properties, which meet the definition of a process
as defined in Topic 805.  Additionally, the Company utilizes the acquired properties to generate rental income as an output
from the properties.  Therefore, the Company believes that each of the three elements of a business is present, and it is
appropriate to apply the business combination guidance (ASC 805) in determining the accounting for its acquisitions.

Where acquisitions are assessed as being
business combinations, the acquisition costs are treated as expenses in the Company’s financial statements. Where acquisitions
are assessed as being asset acquisitions, the acquisition costs are generally capitalized and subsequently amortized as appropriate.

    2

The Company advises the Staff that it will
clarify its disclosure relating to the classification of acquisitions, and provide further disclosure of the effect of such classifications
on its financial statements, in its next Annual Report on Form 10-K.

Form 8-K’s filed on May 7, 2013, June 10, 2013 and
July 24, 2013

 3. We
note that you have presented within each of the above-referenced Form 8-K’s summary financial information for Travis Perkins
plc, Everything Everywhere Limited and Thames Water Utilities Limited, along with disclosure as to where audited financial statements
could be located on the internet for these companies. Please tell us how you have complied with the applicable rules to provide
financial statements of significant asset concentrations as these financial statements have not been filed pursuant to the Exchange
Act.

Although the Staff’s Financial Reporting
Manual (“FRM”) Section 2340 provides that “[a]n asset concentration is generally considered ‘significant’
if it exceeds 20% of the registrant’s assets as of its most recent balance sheet,” FRM Section 2305.5 provides
that in the case of triple net leased properties acquired by a blind pool registrant during its distribution period, significance
should be measured against the “[r]egistrant’s assets as of the date of the acquisition plus the proceeds (net of
commissions) in good faith expected to be raised in the registered offering over the next 12 months.”

As of May 3, 2013, June 7, 2013 and July
19, 2013, the Company’s total assets plus then-anticipated proceeds net of commissions expected to be raised in the registered
offering over the following 12 months were $185.0 million, $224.9 million and $268.9 million, respectively. Measured against these
totals, the acquisitions on those dates comprised approximately 3.3%, 5.5% and 6.8%, respectively. Compared against total assets
plus actual capital raised during the following 12 months, the acquisitions comprised approximately 0.8%, 1.1% and 1.2%, respectively.
As such, the properties were not “significant” for purposes of the test for significant tenant concentration and therefore
financial statements of tenants were not required.

The Company acknowledges 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.

Thank you for your prompt attention to this
letter responding to the Staff’s comments. Please direct any questions concerning this response to the undersigned at (212)
969-3445.

    Yours truly,

    /s/ Peter M. Fass

    Peter M. Fass, Esq.

    cc:
    Michael J. Choate, Esq.

    James A. Tanaka, Esq.

    3

December  15, 201 4

Via E -mail
Mr. Patrick Goulding
Chief Financial Officer
American Realty Capital Global Trust, Inc.
405 Park Avenue , 14th Floor
New York , NY  10022

Re: American Realty Capital Global Trust, Inc.
 Form 10-K for the  fiscal  year ended December  31, 2013
Filed March  7, 201 4
File No. 0-55202

Dear Mr. Goulding :

We have reviewed your filing an d 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 within ten business days 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.

Form 10 -K for the fiscal year ended December 31, 201 3

Item 1. Business, page 5

1. We note that you invest in net leases and that you consider tenant creditworthiness in
your evaluation of inves tment opportunities.   In future filings, please also include a
discussion of how management monitors the tenant credit quality of its current
portfolio.

Mr. Patrick Goulding
 American Realty Capital Global Trust, Inc.
 December  15, 201 4
 Page 2

 Notes to Consolidated Financial Statements

Note 2 – Summary of Significant Accounting Policies

Real Estate Investments, page F -9

2. Please tell us and disclose your policy for determining whether the acquisition of real
estate is a business or asset purchase and the result of that determination on how your
record the cost of the transact ion.  Please ensure you address sale/leaseback transactions
in your disclosure.

Form 8 -K’s filed on May 7, 2013, June 10, 2013 and July 24, 2013

3. We note that you have presented within each of the above -referenced Form 8 -K’s
summary financial information  for Travis Perkins plc, Everything Everywhere Limited
and Thames Water Utilities Limited, along with disclosure as to where audited financial
statements could be located on the internet for these companies.  Please tell us how you
have complied with the a pplicable rules to provide financial statements of significant
asset concentrations as these financial statements have not been filed pursuant to the
Exchange Act.

We urge all 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 ar e 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 proce eding initiated by
the Commission or any person under the federal securities laws of the United States.

Mr. Patrick Goulding
 American Realty Capital Global Trust, Inc.
 December  15, 201 4
 Page 3

 You may contact Howard Efron, Staff Accountant, at (202) 551 -3439 or me at (202) 551 -3629 if
you have questions regarding comments on the financial statements and related matters.  Please
contact Sara von Althann , Staff Attorney, at (202) 551 -3207 or Erin Martin , Staff A ttorney , at
(202) 551 -3391 with regard to legal comments.

Sincerely,

        /s/ Kevin Woody

Kevin Woody
Branch Chief

CORRESP
1
filename1.htm

           Proskauer Rose LLP Eleven Times Square New York, NY
10036-8299

April 16, 2012

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Michael McTiernan

 Re: American Realty Capital Global Daily Net Asset Value Trust, Inc.

Amendment No. 2 to Registration Statement on Form S-11

Filed March 28, 2012

File No. 333-177563

Dear Mr. McTiernan:

On behalf of our client,
American Realty Capital Global Daily Net Asset Value Trust, Inc. (the “Company”), we are submitting this letter
in response to the written comments of the staff (the “Staff”) of the United States Securities and Exchange
Commission (the “Commission”) contained in your letter, dated April 10, 2012 (the “Comment Letter”),
with respect to the registration statement on Form S-11 filed by the Company with the Commission on October 27, 2011 (No. 333-177563)
(the “Registration Statement”), as amended by Amendment No. 1 to the Registration Statement filed by the Company
with the Commission on December 7, 2011 and Amendment No. 2 to the Registration Statement filed by the Company with the Commission
on March 28, 2012.

Certain of the Staff’s
comments call for explanation of, or supplemental information as to, various matters relating to disclosures provided in the Registration
Statement. Responses to these comments have been provided by the Company to us and are set forth in this letter or in Amendment
No. 3 to the Registration Statement (“Amendment No. 3”). Amendment No. 3 has been filed by the Company today.
In addition, we will provide under separate cover certain items requested in this Comment Letter.

The
Company’s responses are set forth below, with the headings and numbered items of this letter corresponding to the headings
and numbered items contained in the Comment Letter. For the convenience of the Staff, each of the comments from the Comment Letter
is restated in bold italics prior to the Company’s response. Capitalized terms used but not defined in this letter shall
have the meanings given to such terms in Amendment No. 3. All page number references in the Company’s responses are to page
numbers in Amendment No. 3.

General

 1. Based on the disclosure throughout the prospectus, it appears that the value to be assigned to the property portfolio
in any future disclosure of NAV per share will be attributed to the valuation expert. Consequently, please confirm that the valuation
expert will file a consent with respect to this disclosure. If the property portfolio value is not intended to be attributed to
the valuation expert, please revise the disclosure to clarify that the advisor is responsible for the value assigned to the property
portfolio, explain in detail how the advisor will exercise its discretion in calculating the property value, and remove the reference
to the valuation expert in the “Experts” section of the prospectus.

April 16, 2012

Page 2

Please note that the valuations of
the Company’s properties will be determined by the advisor, who will take into consideration the appraisals performed
by the independent valuer. The disclosure has been revised to clarify the independent valuer’s and advisor’s
roles in valuing the Company’s properties and to remove the reference to
the independent valuer in the “Experts” section.

Management’s Discussion and Analysis …,
page 139

Liquidity and Capital Resources, page 139

 2. We have considered your revisions in response to comment 13. Please expand your discussion to also disclose the amount
of organizational and offering costs incurred/paid on your behalf subsequent to December 31, 2011, if material.

The disclosure has been revised as requested.

Statement of Cash Flows, page F-6

 3. The amount presented for deferred offering costs paid directly by affiliates is inconsistent with the amount disclosed
within Note 3 on page F-12. Please clarify and revise, as necessary.

Please note that the amount of accrued expenses payable
to affiliates of $170,415 under Note 3 is the sum of the line items “Proceeds from affiliates” (in the amount of $80,040)
and “Deferred offering costs paid directly by affiliates” (in the amount of $90,375) in the Statement of Cash Flows.
Proceeds from affiliates represents funds from affiliates which the Company used to pay offering costs, and Deferred offering costs
paid directly by affiliates represents credit the Company was allowed to apply to SEC, FINRA and Blue Sky fees, which were originally
paid for by ARC — Northcliffe Income Properties, Inc., whose registration statement on Form S-11 was withdrawn
on October 27, 2011.

April 16, 2012

Page 3

Note 2 – Summary of Significant Accounting Policies,
page F-8

 4. Please expand to include your accounting policy for organizational costs. Reference is made to paragraph 720-15-25-1
of FASB Accounting Standards Codification which indicates organizational costs should be expensed as incurred.

The disclosure has been revised as requested.

Table III – Operating Results of Public Program
Properties, page A-8

 5. We note your disclosure in footnote (5) indicating that the Federal tax results for the year ended December 31, 2011
is not available as of the date of the filing. Please update this information after April 15, 2012; to the extent necessary, include
estimated information along with a footnote noting the source of the data and whether the data is subject to adjustment.

Please note that no such information is currently
available as each of the programs has filed for an extension of time to file its tax return by September 15, 2012, and the footnote
has been revised accordingly.

We thank you for your prompt attention
to this letter responding to the Comment Letter and look forward to hearing from you at your earliest convenience. Please direct
any questions concerning this response to the undersigned at (212) 969-3445.

    Yours truly,

    /s/ Peter M. Fass

    Peter M. Fass, Esq.

CORRESP
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American Realty Capital Global Daily
Net Asset Value Trust, Inc.

405 Park Avenue

New York, New York 10022

April 16, 2012

VIA ELECTRONIC TRANSMISSION

AND EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention: Mr. Michael McTiernan

    Re:
    American Realty Capital Global Daily Net Asset Value Trust, Inc.
 File No. 333-177563

Dear Mr. McTiernan:

Pursuant to Rule 461 promulgated under the Securities Act of
1933, as amended, American Realty Capital Global Daily Net Asset Value Trust, Inc. (the “Company”) hereby requests
acceleration of the effective date of the above-referenced Registration Statement, so that it may become effective at 4:00 p.m.
Eastern Time on April 18, 2012, or as soon thereafter as practicable.

The Company acknowledges 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 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,

American Realty Capital Global Daily Net Asset Value Trust,
Inc.

_/s/ Nicholas S. Schorsch____

Nicholas S. Schorsch

Chief Executive Officer

April 10, 2012

 Via E-mail

Nicholas S. Schorsch American Realty Capital Global Daily Net Asset Value Trust, Inc. 405 Park Avenue 15
th Floor
New York, NY 10022

Re: American Realty Capital Global Daily Net Asset Value Trust, Inc.
Amendment No. 2 to Registrati on Statement on Form S-11
Filed March 29, 2012
  File No. 333-177563

Dear Mr. Schorsch:

We have reviewed amendment no. 2 to your 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 re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 General

 1. Based on the disclosure throughout the prospe ctus, it appears that the value to be
assigned to the property portfo lio in any future disclosure  of NAV per share will be
attributed to the valuation expert.  Conseque ntly, please confirm that the valuation expert
will file a consent with respect to this disclosure.  If the property portfolio value is not
intended to be attributed to the valuation e xpert, please revise the disclosure to clarify
that the advisor is responsible for the value as signed to the property portfolio, explain in
detail how the advisor will exercise its disc retion in calculating the property value, and
remove the reference to the valuation expert in the “Experts” secti on of the prospectus.

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. April 10, 2012 Page 2
 Management’s Discussion and Analysis …, page 139

 Liquidity and Capital Resources, page 139

 2. We have considered your revisions in response to comment 13.   Please expand your
discussion to also disclose the amount of or ganizational and offering costs incurred/paid
on your behalf subsequent to December 31, 2011, if material.

Statement of Cash Flows, page F-6

3. The amount presented for deferred offering costs paid directly by affiliates is inconsistent
with the amount disclosed within Note 3 on pa ge F-12.   Please clarify and revise, as
necessary.
Note 2 – Summary of Significant Accounting Policies, page F-8

4. Please expand to include your accounting policy fo r organizational costs.   Reference is
made to paragraph 720-15-25-1 of FASB Accounting Standards Codification which
indicates organizational costs s hould be expensed as incurred.
 Table III – Operating Results of Pu blic Program Properties, page A-8

 5. We note your disclosure in footnote (5) indicatin g that the Federal tax results for the year
ended December 31, 2011 is not available as of the date of the filing.  Please update this
information after April 15, 2012; to the exte nt necessary, include estimated information
along with a footnote noting the source of the data and whether the data is subject to
adjustment.

 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.
Notwithstanding our comments, 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;

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. April 10, 2012 Page 3
  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.
 You may contact Wilson Lee at (202) 551- 3468 or Jessica Barber ich, Assistant Chief
Accountant, at (202) 551-3782 if you have que stions regarding comments on the financial
statements and related matters.  Please contact Stacie Gorman at (202) 551-3585 or me at (202)
551-3852 with any other questions.
Sincerely,
   /s/ Michael McTiernan   Michael McTiernan
Assistant Director
cc: Peter M. Fass, Esq. ( via e-mail )

CORRESP
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American Realty Capital Global Daily
Net Asset Value Trust, Inc.

405 Park Avenue

New York, New York 10022

March 30, 2012

VIA ELECTRONIC TRANSMISSION

AND EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention: Mr. Michael McTiernan

    Re:
    American Realty Capital Global Daily Net Asset Value Trust, Inc.
 File No. 333-177563

Dear Mr. McTiernan:

Reference is made to the Acceleration Request
(the “Acceleration Request”) submitted to the Securities and Exchange Commission (“ Commission ”)
by American Realty Capital Global Daily Net Asset Value Trust, Inc. (the “Company”) on March 28, 2012, relating
to the above-referenced Registration Statement on Form S-11 (the “Registration Statement”).  The Company
hereby applies to the Commission for the withdrawal of the Acceleration Request, effective as of the date of this application or
as soon as practicable thereafter.

If you have questions or require additional
information, please do not hesitate to contact the Company’s counsel Peter M. Fass at (212) 969-3445.

Very truly yours,

American Realty Capital Global Daily Net Asset Value, Inc.

         /s/
Nicholas S. Schorsch

Nicholas S. Schorsch

Chief Executive Officer

CORRESP
1
filename1.htm

American Realty Capital Global Daily
Net Asset Value Trust, Inc.

405 Park Avenue

New York, New York 10022

March 28, 2012

VIA ELECTRONIC TRANSMISSION

AND EDGAR

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, NE

Washington, DC 20549

Attention: Mr. Michael McTiernan

    Re:
    American Realty Capital Global Daily Net Asset Value Trust, Inc.
 File No. 333-177563

Dear Mr. McTiernan:

Pursuant to Rule 461 promulgated under the Securities Act of
1933, as amended, American Realty Capital Global Daily Net Asset Value Trust, Inc. (the “Company”) hereby requests
acceleration of the effective date of the above-referenced Registration Statement, so that it may become effective at 4:00 p.m.
Eastern Time on March 30, 2012, or as soon thereafter as practicable.

The Company acknowledges 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 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,

American Realty Capital Global Daily Net Asset Value Trust,
Inc.

_/s/ Nicholas S. Schorsch__

Nicholas S. Schorsch

Chief Executive Officer

CORRESP
1
filename1.htm

    Proskauer Rose LLP   Eleven Times Square   New York, NY  10036-8299

March 28, 2012

United States Securities and Exchange Commission

Division of Corporation Finance

100 F Street, N.E.

Washington, D.C. 20549

Attn: Michael McTiernan

    Re:
    American Realty Capital Global Daily Net Asset Value, Inc.

    Amendment No. 2  to Registration Statement on Form S-11

    Filed March 28, 2012

    File No. 333-177563

Dear Mr. McTiernan:

On
behalf of our client, American Realty Capital Global Daily Net Asset Value Trust, Inc. (the “Company”), we
are submitting this letter in response to the written comments of the staff (the “Staff”) of the United States
Securities and Exchange Commission (the “Commission”) contained in your letter, dated January 4, 2012 (the
“Comment Letter”), with respect to the registration statement on Form S-11 filed by the Company with the Commission
on October 27, 2011 (No. 333-177563) (the “Registration Statement”), as amended by Amendment No. 1 to the Registration
Statement filed by the Company with the Commission on December 7, 2011.

Certain
of the Staff’s comments call for explanation of, or supplemental information as to, various matters relating to disclosures
provided in the Registration Statement. Responses to these comments have been provided by the Company to us and are set forth
in this letter or in Amendment No. 2 to the Registration Statement (“Amendment No. 2”). Amendment No. 2 has
been filed by the Company today. In addition, we will provide under separate cover certain items requested in this Comment Letter.

The
Company’s responses are set forth below, with the headings and numbered items of this letter corresponding to the headings
and numbered items contained in the Comment Letter. For the convenience of the Staff, each of the comments from the Comment Letter
is restated in bold italics prior to the Company’s response. Capitalized terms used but not defined in this letter shall
have the meanings given to such terms in Amendment No. 2. All page number references in the Company’s responses are to page
numbers in Amendment No. 2.

General

    1.
    We note your response to comment 4 of our letter dated November 23, 2011.  Please note that you are responsible for analyzing the applicability of Regulation M to your share repurchase program.  We are not taking a position on the conclusions described in your response.

    The Company acknowledges it is responsible for analyzing the applicability of Regulation M to its share repurchase program.

March 28,
2012
 Page 2

    2.
    We note your response to comment 5.  Please revise the last full paragraph on page 6 and the second paragraph on page 203 to clarify that the advisor will review the valuation estimate established by the independent valuer for consistency with your valuation guidelines and the reasonableness of the conclusions and may in its discretion consider other factors in calculating the NAV.  Please include similar disclosure regarding the advisor’s authority to review and adjust the values determined by the independent valuer in the new risk factor on page 34.

    The disclosures have been revised as requested.

    3.
    We note your disclosure on pages 36, 102, and 143 regarding the proceeds raised by American Realty Capital (“ARC”) Properties.  We note that on pages 102 and 143 you provide different amounts of net proceeds raised and that on page 36 you disclose the gross proceeds.  Please revise your disclosure on pages 102 and 143 as appropriate to address the discrepancy in the amounts and please ensure that your disclosure on page 36 is accurate.

    The disclosure has been revised as requested.  Please note the amount of aggregate proceeds received by American Realty Capital Properties, Inc. is approximately $83.9 million.

Prospectus Cover Page

    4.
    We note your response to comment 7 of our letter dated November 23, 2011.  Please confirm that the cover page of the prospectus delivered to investors will have at least a 10 point modern type font as required by Rule 420 of Regulation C.  If necessary, please consider removing disclosure not required by Item 501 of Regulation S-K or Industry Guide 5.

    The Company confirms that the cover page of the prospectus delivered to investors will have at least a 10 point modern type font as required by Rule 420 of Regulation C.

    5.
    We note your response to comment 8 of our letter dated November 23, 2011.  Please disclose the number of other programs currently managed by your sponsor.  Please make similar revisions to your disclosure on page 8.

    The disclosure has been revised as requested.

    6.
    Please revise your cover page to provide disclosure regarding the shares to be offered pursuant to your dividend reinvestment plan.  Please refer to Item 501 of Regulation S-K.

    The disclosure has been revised as requested.

March 28, 2012

Page 3

What is the purchase
price for shares of our common stock?, page 6

    7.
    We
    note your intention to file a monthly pricing supplement.  Prior to effectiveness, please provide us a draft of the monthly
    supplement.  The monthly supplement should prominently disclose the website address and phone number where the most recent
    price may be obtained and should include disclosure of the NAV per share for each of the business days in the prior month.
    In addition, to the extent the NAV per share deviates by more than 5% from the price disclosed in the most recently filed
    prospectus, please confirm that you will file an updated pricing supplement.

    Enclosed please find a draft monthly supplement for your review.  We confirm that an
    updated pricing supplement will be filed in the event there is a change in NAV of more than 5% from the NAV in the most recently
    filed prospectus or supplement.

How will your advisor
calculate NAV per share?, page 7

    8.
    Please
    disclose in this section that the fees that you pay your advisor and other affiliates that are based on NAV will be higher
    because you are amortizing certain costs over the five-year period, resulting in a higher NAV.  Additionally, please
    disclose that this will result in investors paying a higher price than if these costs were not amortized.

    The disclosure has been revised as requested.

    9.
    We
    note your response to comment 13 of our letter dated November 23, 2011.  We reissue our comment.  Please revise
    to clarify whether the independent valuer will also value the liabilities.  For example, the disclosure on page 34 indicates
    the independent valuer will value liabilities but the disclosure on page 126 indicates that the advisor will perform this
    calculation.

    Please note that the independent valuer will perform appraisals of the real estate assets
    and the liabilities will be valued by the advisor.  The disclosure has been revised accordingly.

What are your exit
strategies?, page 11

    10.
    We
    note your response to comment 17 of our letter dated November 23, 2011.  Please revise to clarify whether the three to
    six year period is measured from the conclusion of the offering covered by this registration statement, or the conclusion
    of the offering as may be extended via a follow-on registration statement.  In addition, please disclose in this section
    that your intended liquidity events are subject to the board determining it is appropriate to commence a liquidity event and
    that a majority of your shareholders will need to approve a liquidity event.  Please clarify, if true, that you may continue
    indefinitely if a majority of your shareholders do not approve a liquidity transaction.  Please also revise your disclosure
    on page 118 as appropriate.

    The three to six year period is measured
    from the conclusion of the offering covered by the registration statement and not as it may be extended through any follow-on.
    The disclosure has been revised accordingly.

March 28, 2012

Page 4

What are the fees
that you will pay …?, page 14

    11.
    We
    note your disclosure that you will pay your advisor a subordinated participation fee or subordinated incentive fee equal to
    15%.  However, on page F-12, you indicate that these fees will equal 25%.  Please revise, as appropriate, to correct
    this discrepancy.

    The disclosure has been revised as requested.  Please note the correct percentage is
    15%.

Valuation Policies,
page 125

    12.
    We
    note your response to comment 28 of our letter dated November 23, 2011.  We will continue to monitor for your response
    to this comment.

    Please note that the advisor will evaluate the calculations determined by the independent valuer immediately
    following receipt of the respective calculations. The advisor has extensive experience with respect to acquiring properties meeting the investment
    strategy as detailed within the prospectus and such experience has resulted in the advisor's having expertise as it relates to evaluating assumptions
    used to determine the value of an investment property. In particular, the advisor compares and evaluates information contained within the valuation report
    to internal files developed over time in connection with prior acquisitions and market data. Such inputs include comparable sales figures, replacement
    cost as well as capitalization rates taking the tenants' credit worthiness into account.

    In the absence of any errors or deviations from the valuation guidelines, the advisor does not intend to adjust the
    value as determined by the independent valuer in its final report. Rather, the advisor will discuss their findings relative to information provided
    within such report in the interest of ensuring no material misstatements or oversights were included within the calculation determining value.

Management’s
Discussion and Analysis of Financial Condition and Results of Operation, page 131

Liquidity and Capital
Resources, page 131

    13.
    Please
    expand your discussion to disclose the amount of organizational and offering costs incurred/paid on your behalf to date.
    Also, expand your footnotes to include your accounting policy for organizational costs.

    The disclosure has been revised as requested.

Table I, page A-2

    14.
    We
    note your response to comment 33.  We still do not understand how this ratio can be negative.  Assuming this issue
    is addressed, we do not object to the presentation given the clarifying footnotes.  However, please note that we would
    also not object to the inclusion of the ratios in the footnotes directly in the table.  The total acquisition cost for
    purposes of the percentage leverage row in Table I may include the portion of the acquisition cost financed through a mortgage.

    Please note that the presentation of information in Table I was determined in response to
    a comment received by the Company on a different offering sponsored by the American Realty Capital group of companies. In
    particular, the comment came from Attorney-Advisor Mr. Duc Dang on Amendment no. 3 to the Registration Statement on Form S-11
    of American Realty Capital – Retail Centers of America, Inc. (File No. 333-169355), filed February 4, 2011.

March 28, 2012

Page 5

Draft
Opinions

    15.
    We
    note your response to comment 37 of our letter dated November 23, 2011.  Please file these opinions as part of your correspondence
    on EDGAR.

    Please note that the opinions have been filed as exhibits to the Registration Statement.

We thank you
for your prompt attention to this letter responding to the Comment Letter and look forward to hearing from you at your earliest
convenience. Please direct any questions concerning this response to the undersigned at (212) 969-3445.

    Yours truly,

    /s/ Peter M. Fass

    Peter M. Fass, Esq.

Dated: _______, 2012

Monthly Pricing Supplement

(unaudited)

On _______, 2012, our net asset value (“NAV”)
per institutional share is $__ and our NAV per retail share is $__.

The NAV per share for a particular day
can be found on our Web site at www.arcglobalnav.com or by calling our toll-free, automated telephone line at 1-866-532-4743.

The following sets forth the calculation of NAV for
each of the institutional and retail shares:

    Net Asset Value as of _______, 2012 [DATE BEFORE CALCULATION DATE]:
    $ [●]

    Net Assets as of _______, 2012:

    Real Estate Properties, at Fair Value
    $ —

    Non-Real Estate Assets (1)

    Cash and Cash Equivalents
      [●]

    Accrued Rental Income
      —

    Prepaid Organizational and Other Costs
      [●]

    Total Net Assets
      [●]

    Liabilities

    Financing

    Other Liabilities (1)
      [●]

    Total liabilities
      [●]

    Net Asset Value
    $ [●]

(1)  As described in “Valuation Policies” in our Prospectus, the Company estimates
operating income and certain expenses and adds, or deducts, the daily accrual of such estimated expenses in determining Net Asset
Value. Any operating income or such expense items that exceed the amount of such estimates will be adjusted monthly on a going
forward basis.

The Real Estate Properties have initially been valued at
cost. After such initial valuations, the value of the Real Estate Properties will be determined based in part on the valuations
performed by Duff & Phelps, LLC, an independent valuation firm retained by us, which will be performed on each property at
least one calender quarter after its acquisition. Based on historical operations, the value of the Real Estate Properties represents
an 8.8% capitalization rate.

Daily Adjustment and Calculation of NAV

Institutional Shares

      NAV

    Net Asset Value for Institutional shares as of _______, 2012 [DATE BEFORE CALCULATION DATE]:
    $ ___($___ )

    Share Purchases and Redemptions, _______, 2012 [DATE BEFORE CALCULATION DATE]:

    Share Purchases
      —

    Share Redemptions
      —

    Daily activity for _______, 2012: (2)

    Accrual of Portfolio Revenue
      —

    Accrual of Asset Management Fee
      —

    Accrual of Other Expenses (3)
      —

    Accrual of Organizational and Offering Expenses
      —

    Change in NAV due to Gains (Losses) (Realized and Unrealized) on Assets and Liabilities subsequent to _______, 2012

    Ending NAV on _______, 2012 (per institutional share)
    $ ___($___ )

Retail Shares

      NAV

    Net Asset Value for Retail shares as of _______, 2012 [DATE BEFORE CALCULATION DATE]:
    $ ___($___ )

    Share Purchases and Redemptions, _______, 2012 [DATE BEFORE CALCULATION DATE]:

    Share Purchases
      [●]

    Share Redemptions
      —

    Daily activity for _______, 2012: (2)

    Accrual of Portfolio Revenue
      —

    Accrual of Asset Management Fee
      —

    Accrual of Other Expenses (3)
      —

    Accrual of Organizational and Offering Expenses
      —

    Change in NAV due to Gains (Losses) (Realized and Unrealized) on Assets and Liabilities subsequent to _______, 2012

    Ending NAV on _______, 2012 (per retail share)
    $ ___($___ )

(2)   The beginning NAV and the Daily Activity for _______, 2012 have been allocated between
the institutional shares and the retail shares in proportion to the NAV of the institutional shares and the retail shares on _______,
2012.

(3)   Other Expenses, consist of all of our operating and administrative expenses, other
than asset management fees and organizational and offering expenses.

Below is the NAV per share for each of the retail institutional
shares and the retail shares for each day subsequent to our last pricing supplement.

    Date

        NAV per institutional

        share

    NAV per retail share

    ___________, 2012*
    $[__]
    $[__]

    ___________, 2012
    $[__]
    $[__]

    ___________, 2012
    $[__]
    $[__]

    ___________, 2012**
    $[__]
    $[__]

*

January 4, 2012
Via E-mail

Nicholas S. Schorsch American Realty Capital Global Daily Net Asset Value Trust, Inc. 405 Park Avenue
15
th Floor
New York, NY 10022
Re: American Realty Capital Global Daily Net Asset Value Trust, Inc.
Amendment No. 1 to Registrati on Statement on Form S-11
Filed October 27, 2011
  File No. 333-177563

Dear Mr. Schorsch:

We have reviewed amendment no. 1 to your 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 re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 General

 1. We note your response to comment 4 of our le tter dated November 23, 2011.  Please note
that you are responsible for analyzing the a pplicability of Regulation M to your share
repurchase program.  We are not taking a posit ion on the conclusions described in your
response.

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. January 4, 2012 Page 2
 2. We note your response to comment 5.  Please re vise the last full pa ragraph on page 6 and
the second paragraph on page 203 to clarify th at the advisor will re view the valuation
estimate established by the independent valu er for consistency with your valuation
guidelines and the reasonableness of the conc lusions and may in its discretion consider
other factors in calculating the NAV.  Please include similar disclo sure regarding the
advisor’s authority to review and adjust the values determined by the independent valuer
in the new risk factor on page 34.
 3. We note your disclosure on pages 36, 102, and 143 regarding the proceeds raised by
American Realty Capital (“ARC”) Propertie s.  We note that on pages 102 and 143 you
provide different amounts of net proceeds ra ised and that on page 36 you disclose the
gross proceeds.  Please revise your disclo sure on pages 102 and 143 as appropriate to
address the discrepancy in the amounts and plea se ensure that your disclosure on page 36
is accurate.

Prospectus Cover Page

 4. We note your response to comment 7 of our  letter dated November 23, 2011.  Please
confirm that the cover page of the prospectus delivered to investors will have at least a 10
point modern type font as required by Rule  420 of Regulation C.  If necessary, please
consider removing disclosure  not required by Item 501 of Regulation S-K or Industry
Guide 5.

5. We note your response to comment 8 of our  letter dated November 23, 2011.  Please
disclose the number of other programs cu rrently managed by your sponsor.  Please make
similar revisions to your disclosure on page 8.

6. Please revise your cover page to provide disc losure regarding the shares to be offered
pursuant to your dividend reinve stment plan.  Please refer to  Item 501 of Regulation S-K.
 What is the purchase price for shar es of our common stock?, page 6

 7. We note your intention to file a monthly pric ing supplement.  Prior to effectiveness,
please provide us a draft of the monthly s upplement.  The monthly supplement should
prominently disclose the website address a nd phone number where the most recent price
may be obtained and should include disclo sure of the NAV per share for each of the
business days in the prior month.  In additi on, to the extent the NAV per share deviates
by more than 5% from the price disclosed in  the most recently filed prospectus, please
confirm that you will file an updated pricing supplement.

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. January 4, 2012 Page 3
 How will your advisor calculate NAV per share?, page 7

 8. Please disclose in this secti on that the fees that you pay your  advisor and other affiliates
that are based on NAV will be higher because  you are amortizing certain costs over the
five year period, resulting in a higher NAV.  Additionally, please  disclose that this will
result in investors paying a higher price than if these costs were not amortized.

9. We note your response to comment 13 of our letter dated November 23, 2011.  We
reissue our comment.  Please revise to clarif y whether the independent valuer will also
value the liabilities.  For example, the disc losure on page 34 indi cates the independent
valuer will value liabilities but the disclosu re on page 126 indicates that the advisor will
perform this calculation.
 What are your exit strategies?, page 11

 10. We note your response to comment 17 of our  letter dated November 23, 2011.  Please
revise to clarify whether the three to six y ear period is measured from the conclusion of
the offering covered by this registration statem ent, or the conclusion of the offering as
may be extended via a follow-on registration stat ement.  In addition, please disclose in
this section that your intended liquidity events  are subject to the boa rd determining it is
appropriate to commence a liquidity event and that a majority of your shareholders will
need to approve a liquidity event.  Pleas e clarify, if true, that you may continue
indefinitely if a majority of your sharehol ders do not approve a liquidity transaction.
Please also revise your disclosu re on page 118 as appropriate.

What are the fees that you will pay …?, page 14

11. We note your disclosure that you will pay your advisor a subordinated participation fee or
subordinated incentive fee equal to 15%.  Ho wever, on page F-12, you indicate that these
fees will equal 25%.  Please revise, as appropriate, to correct this discrepancy.
 Valuation Policies, page 125

 12. We note your response to comment 28 of our  letter dated November 23, 2011.  We will
continue to monitor for your response to this comment.
 Management’s Discussion and Analysis of Fina ncial Condition and Results of Operation, page
131
 Liquidity and Capital Resources, page 131

 13. Please expand your discussion to disclose the amount of organizational and offering costs
incurred/paid on your behalf to date.  Al so, expand your footnotes to include your
accounting policy for orga nizational costs.

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. January 4, 2012 Page 4
 Table I, page A-2

 14. We note your response to comment 33.  We s till do not understand how this ratio can be
negative.  Assuming this issue is addressed, we  do not object to the presentation given the
clarifying footnotes.  However, please note that we would also  not object to the inclusion
of the ratios in the footnotes directly in the table.  The to tal acquisition cost for purposes
of the percentage leverage row in Table I ma y include the portion of  the acquisition cost
financed through a mortgage.
Draft Opinions

15. We note your response to comment 37 of our letter dated November 23, 2011.  Please file
these opinions as part of your correspondence on EDGAR.
 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.
Notwithstanding our comments, 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.

Nicholas S. Schorsch
American Realty Capital Global Daily Net Asset Value Trust, Inc. January 4, 2012 Page 5
 You may contact Wilson Lee at (202) 551- 3468 or Jessica Barber ich, Assistant Chief
Accountant, at (202) 551-3782 if you have que stions regarding comments on the financial
statements and related matters.  Please contact Stacie Gorman at (202) 551-3585 or me at (202)
551-3852 with any other questions.
Sincerely,
   /s/ Michael McTiernan   Michael McTiernan
Assistant Director
cc: Peter M. Fass, Esq. ( via e-mail )

CORRESP
1
filename1.htm

    Unassociated Document

The Tower at Peabody Place

John A. Good

100 Peabody Place, Suite 900

phone:       (901) 543-5901

Memphis, TN  38103-3672

fax:           (888) 543-4644

(901) 543-5900

e-mail:      jgood@bassberry.com

December 7, 2011

Michael McTiernan

Assistant Director

U.S. Securities and Exchange Commission

Washington, DC  20549

Re:         American Realty Capital Global Daily Net Asset Value Trust, Inc.

Registration Statement on Form S-11

Filed October 27, 2011

File No. 333-177563

Dear Mr. McTiernan:

As counsel to American Realty Capital Global Daily Net Asset Value Trust, Inc., a Maryland corporation organized to qualify as a real estate investment trust (the “Company”), we are transmitting for filing pursuant to the Securities Act of 1933, as amended (the “Securities Act”), Pre-Effective Amendment No. 1 (“Amendment No. 1”) to the Company’s Registration Statement on Form S-11 (File No. 333- 177563) (the “Registration Statement”) and the Company’s responses to the comments of the Staff of the Division of Corporation Finance (the “Staff”) of the Securities and Exchange Commission (the “Commission”) contained in your letter dated November 23, 2011.

For convenience of reference, each Staff comment in your November 23, 2011 comment letter is reprinted below in italics, numbered to correspond with the paragraph numbers assigned in your letter, and is followed by the corresponding response of the Company.

We are providing to each of you and Stacie Gorman a courtesy copy of this letter and two courtesy copies of Amendment No. 1 filed by the Company on the date hereof, one copy of which has been marked to reflect changes made to the Registration Statement filed with the Commission on October 27, 2011 (the “Blackline”).  The changes reflected in Amendment No. 1 have been made in response to the Staff’s comments and for the purpose of updating and revising certain information in the Registration Statement.  All page references in our responses are to the pages of the Blackline.  Capitalized terms used and not otherwise defined in this response letter that are defined in the Registration Statement shall have the meanings set forth in the Registration Statement.

General

Comment 1.  We note your disclosure on page 181 regarding the share redemption program.  Please provide us with a detailed legal analysis of the applicability of the tender offer rules, including Rule 13e-4 and Regulation 14E, to your share repurchase program.  We urge you to consider all the elements of your share repurchase program in determining whether the program is consistent with relief granted by the Division of Corporation Finance in prior no action letters.  See, for example, T REIT Inc. (Letter dated June 4, 2001) and Well Real Estate Investment Trust II, Inc. (Letter dated December 3, 2003).  To the extent you have questions as to whether the program is entirely consistent with the relief previously granted by the Division of Corporation Finance, you may contact the Division’s Office of Mergers and Acquisitions.  Please note that we will refer your response to the Office of Mergers and Acquisitions for further review.

December 7, 2011

Page 2

Response 1.  The Company’s share redemption program is not a tender offer and not subject to the tender offer rules, including Rule 13e-4 and Regulation 14E.  The share redemption program is consistent with the share redemption program of American Realty Capital Daily Net Asset Value Trust, Inc. (“ARC-NAV”), which was granted no action relief on July 21, 2011.

In granting no action relief to ARC-NAV, the SEC relied on the following facts:  (i) all material information and modifications related to the redemption program will be fully and timely disclosed to stockholders in the prospectus and the NAV per share will be available on the company’s web site and toll-free information line; (ii) the company will not solicit redemptions other than through the prospectus and prospectus supplements disclosing the NAV per share; (iii) the shares will be redeemed daily at the published NAV per share for each class of shares being redeemed; (iv) the redemption price will be paid no later than three business days following a redemption request and will be the same for all shares of the same class being redeemed on a given day; (v) redemptions will be limited in any calendar quarter to shares whose aggregate value is 5% of the combined NAV of both classes of shares as of the last calendar quarter and or an aggregate limit of approximately 20% of the company’s total NAV for a 12-month period; (vi) redemptions on a first-come, first-served basis during each calendar quarter; (vii) stockholders may cancel redemption requests by notifying a customer service representative at the company’s toll-free information line; (viii) there will be no established trading market for the company’s common stock and the redemption program will be terminated if the company’s shares are listed on a national securities exchange or included for quotation on a national securities market, or in the event a secondary market for the company’s shares develops; (ix) the redemption program is intended to remain open for the life of the company unless modified or suspended by the board of directors; and (x) the redemption program is open to all stockholders on the same terms, subject to a short-term trading fee if stockholders have held their shares for less than four months.  As disclosed in the prospectus, the Company’s share redemption program is consistent with the foregoing qualifications; therefore, we believe that the tender offer rules do not apply.

Comment 2.  Please submit all written sales materials proposed to be transmitted to prospective investors, orally or in writing, including that intended for broker-dealer use only.  Please be aware that we will need time to review these materials.  In addition, note that sales materials must set forth a balanced presentation of the risks and rewards to investors and should not contain any information or disclosure that is not contained in or derived from the prospectus.  For guidance, refer to Item 19.D of Industry Guide 5.

Response 2.  Currently no drafts of written sales materials proposed to be transmitted to prospective investors exist.  In response to the Staff’s comment, the Company undertakes to provide to the Staff all written sales materials proposed to be transmitted to prospective investors, orally or in writing, including that intended for broker-dealer use only.

Comment 3.  Please provide us with copies of any graphics, maps, photographs, and related captions or other artwork including logos that you intend to use in the prospectus.  Such graphics and pictorial representations should not be included in any preliminary prospectus distributed to prospective investors prior to our review.

Response 3.  In response to the Staff’s comment, prior to effectiveness, the Company undertakes to provide copies of any graphics, maps, photographs, and related captions or other artwork, that it intends to use in the prospectus.

Comment 4.  We note that you may conduct the share repurchase program during the offering period of the shares being registered under this registration statement.  Please be advised that you are responsible for analyzing the applicability of Regulation M to your share repurchase program.  We urge you to consider all the elements of your share repurchase program in determining whether the program is consistent with the class relief granted by the Division of Market Regulation in the class exemptive letter granted Alston & Bird LLP dated October 22, 2007.  To the extent you have questions as to whether the program is entirely consistent with that class exemption you may contact the Division of Market Regulation.

December 7, 2011

Page 3

Response 4.  The Company’s share repurchase program is consistent with the class relief previously granted by the Division of Market Regulation in the class exemptive letter granted Alston & Bird LLP dated October 22, 2007.  With respect to the Company’s share repurchase program during the offering period, we respectfully note the following: there is no trading market for the Company’s common stock; the Company will terminate its share repurchase program during the distribution of its common stock in the event that a secondary market for the Company’s common stock develops; the Company purchases shares of its common stock under its share repurchase program at a price based on the NAV per share, which is the same metric used to set the price for the Company’s common stock; the terms of the share repurchase program are fully disclosed in the Company’s prospectus; and except as otherwise exempted therein, the Company shall comply with Regulation M.

Comment 5.  Please advise us whether the independent valuer will file a Rule 436 consent with respect to the disclosure of the property portfolio and liability values.  We note that you have identified the valuer as an “expert” on page 211.

Response 5.  The independent valuer will not qualify as an “expert” and therefore will not file a Rule 436 consent.

Comment 6.  Please add disclosure in the summary section that the NAV calculation is an estimate and that organizational and offering costs are amortized over five years.

Response 6.  In response to the Staff’s comment, the Company has added disclosure in the summary section on page 6 that the NAV calculation is an estimate and that organizational and offering costs are amortized over five years.

Cover Page

Comment 7.  Please ensure that your cover page does not exceed one page in length as required by Item 501(b) of Regulation S-K.  The cover page should be limited to information required by Item 501 and other information that is key to an investment decision.  Some of the details of the offering may be more appropriate for the prospectus summary or the body of the prospectus.

Response 7.  The Company has limited its cover page to one page in length as required by the applicable rules.

Comment 8.  Please add a cover page and summary risk factor relating to the competing time demands imposed on the sponsor by all the other public programs it is currently managing.

Response 8.  In response to the Staff’s comment, the Company has added the requested disclosure.

Comment 9.  Please clarify that the shares sold pursuant to the dividend reinvestment plan will also be based on your net asset value.

Response 9.  In response to the Staff’s comment, the Company has clarified on the cover page that the shares sold pursuant to the dividend reinvestment plan will also be based on the net asset value of the common stock.

December 7, 2011

Page 4

Investment Objectives, page 2

Comment 10.  We note your disclosure in this section that you will seek to invest 25% of your capital in Europe.  However, on page 62 and elsewhere, you indicate that you may invest up to 40% of your capital in Europe.  Further, you indicate that up to 10% of your investments may be made elsewhere internationally.  Please revise your disclosure as appropriate.

Response 10.  In response to the Staff’s comment, the Company has revised its disclosure to more clearly indicate the respective percentages of assets to be invested in the United States, Europe and elsewhere internationally.

How is an investment in shares of your common stock different from listed REITs? , page 2

Comment 11.  Please provide a more balanced comparison with listed REITs.  For example, please disclose that common stock in a listed REIT is more liquid than your common stock.

Response 11.  In response to the Staff’s comment, the Company has provided additional disclosure regarding an investment in shares of the Company’s common stock and that of a listed REIT.

Who are your advisor and service providers and what will they do?, page 3

Comment 12.  Please revise to identify the European service provider you intend to use.

Response 12.  The Company respectfully submits that it has not yet contracted with a European service provider.  Further, as disclosed in the prospectus, the Company, through its advisor, may engage more than one service provider for its international investments.

How will your advisor calculate NAV per share?, page 6

Comment 13.  Please revise to clarify that the independent valuer will also value the liabilities.  Please also provide more detailed disclosure of any adjustments the advisor might make to the values calculated by the independent valuer.

Response 13.  In response to the Staff’s comment, the Company has revised its disclosure on page 6.

Who should buy shares?, page 9

Comment 14.  We note that you refer to yourself as a finite-life entity.  However, we note that you are not required to liquidate by a specific date and that your board may determine when you should commence a liquidity event.  Please revise your disclosure to clarify this point.

Response 14.  In response to the Staff’s comment, the Company has revised its disclosure on pages i and 9 to clarify this point.

Will you use debt borrowing to finance your investments?, page 11

Comment 15.  Please revise to disclose the amount of leverage you are permitted to incur under your charter.

Response 15.  In response to the Staff’s comment, the Company has included the requested disclosure on page 11.

What are your exit strategies?, page 11

Comment 16.  We note your disclosure that you intend to begin a liquidity event in three to six years after the offering.  However, on page 114 and elsewhere, you state that you intend to begin a liquidity event in six to eight years.  Further, on page 130, you state that you intend to begin a liquidity event in three to five years.  Please revise your disclosure as appropriate to clarify this discrepancy.

December 7, 2011

Page 5

Response 16.  It is the Company’s intention to begin a liquidity event three to six years after the termination of the offering period.  In response to the Staff’s comment, the Company has revised its disclosure throughout the prospectus to clarify its intended timeframe for a liquidity event.

Comment 17.  Please revise to disclose that your intended liquidity events are subject to the board determining it is appropriate to commence a liquidity event and that shareholders must approve a proposed liquidity event.  Please revise to clarify, if true, that you may continue indefinitely if your shareholders do not approve your proposed liquidity transactions.

Response 17.  In response to the Staff’s comment, the Company has revised its disclosure beginning on page 118.

What conflicts of interest will your advisor . . . ? ., page 12

Comment 18.  Please disclose the respective interest held in your sponsor by Messrs. Schorsch and Kahane.

Response 18.  In response to the Staff’s comment, the Company has included the requested disclosure on page 13.

What are the fees that you will pay . . .?, page 14

Comment 19.  Please clarify how your advisors and sub-advisors will be compensated if you enter into a joint venture with an affiliate.

Response 19.  The Company does not currently intend to enter into a joint venture with affiliates.  The Company respectfully submits that it is unable to provide the exact terms of compensation in the unlikely event that the advisor or any service provider enters into a joint venture with an affiliate because these terms will be dependent upon the assets of the joint venture under the criteria described in the prospectus, as well as the financial condition and operating capabilities of the prospective partner at the given time.  Such factors will be unknown until such a joint venture is formed, if at all.  As disclosed in the prospectus, joint ventures with affiliates must be approved by a majority of the Company’s independent directors as being fair and reasonable and upon substantially the same terms and conditions as those received by the ot

November 23, 2011
 Via E-mail

Nicholas S. Schorsch Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. 405 Park Avenue 15
th Floor
New York, NY 10022

Re: American Realty Capital Global Daily Net Asset Value Trust, Inc.
Registration Statement on Form S-11 Filed October 27, 2011
  File No. 333-177563

Dear Mr. Schorsch:

We have reviewed your registration statem ent and have the following comments.  In
some of our comments, we may ask you to provi de 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 re gistration statement and the information you
provide in response to these comments, we may have additional comments.
 General

 1. We note your disclosure on page 181 regardi ng the share redemption program.  Please
provide us with a detailed legal analysis of  the applicability of the tender offer rules,
including Rule 13e-4 and Regulation 14E, to your share repurchase program.  We urge
you to consider all the elements of your  share repurchase program in determining
whether the program is consistent with re lief granted by the Division of Corporation
Finance in prior no action letters. See, for example, T REIT Inc. (Letter dated June 4, 2001) and Wells Real Estate I nvestment Trust II, Inc. (Le tter dated December 3, 2003).
To the extent you have questions as to whether the program is entirely consistent with the
relief previously granted by the Division of  Corporation Finance, you may contact the
Division’s Office of Mergers and Acquisitions.  Please note  that we will refer your
response to the Office of Mergers an d Acquisitions for further review.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 2
 2. Please submit all written sales materials pr oposed to be transmitted to prospective
investors, orally or in writing, including that  intended for broker-dealer use only.  Please
be aware that we will need time to review th ese materials.  In addition, note that sales
materials must set forth a balanced presentati on of the risks and rewards to investors and
should not contain any informati on or disclosure that is not contained in or derived from
the prospectus.  For guidance, refe r to Item 19.D of Industry Guide 5.

3. Please provide us with copies of any graphi cs, maps, photographs, and related captions or
other artwork including logos th at you intend to use in the pr ospectus.  Such graphics and
pictorial representations should not be included in any prelim inary prospectus distributed
to prospective investor s prior to our review.

4. We note that you may conduct the share repurch ase program during the offering period of
the shares being registered under this registra tion statement.  Please be advised that you
are responsible for analyzing the applicabil ity of Regulation M to your share repurchase
program.  We urge you to consider all the el ements of your share repurchase program in
determining whether the program is consis tent with the class relief granted by the
Division of Market Regulation in the class ex emptive letter granted Alston & Bird LLP
dated October 22, 2007.  To the extent you have questions as to whether the program is
entirely consistent with that class exemp tion you may contact the Division of Market
Regulation.

5. Please advise us whether the independent valu er will file a Rule 436 consent with respect
to the disclosure of the property portfolio and liability values.  We note that you have
identified the valuer as an “expert” on page 211.

6. Please add disclosure in the summary section that the NAV calculation is an estimate and
that organizational and offering cost s are amortized over five years.

Cover Page

 7. Please ensure that your cover page does not  exceed one page in length as required by
Item 501(b) of Regulation S-K.  The cove r page should be limited to information
required by Item 501 and other information that is key to an investment decision.  Some
of the details of the offering may be more a ppropriate for the prosp ectus summary or the
body of the prospectus.
8. Please add a cover page and summary risk f actor relating to the competing time demands
imposed on the sponsor by all the other publ ic programs it is currently managing.
 9. Please clarify that the shares sold pursuant to the dividend reinvestment  plan will also be
based on your net asset value.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 3
 Investment Objectives, page 2

 10. We note your disclosure in this section that you will seek to invest 25% of your capital in
Europe.  However, on page 62 and elsewhere,  you indicate that you may invest up to
40% of your capital in Europe. Further, you in dicate that up to 10% of your investments
may be made elsewhere internationally.  Pl ease revise your disclo sure as appropriate.
 How is an investment in shares of your co mmon stock different from listed REITs?, page 2

 11. Please provide a more balanced comparison with listed REITs.  For example, please
disclose that common stock in a listed RE IT is more liquid than your common stock.

Who are your advisor and service provide rs and what will they do?, page 3

 12. Please revise to identify the European  service provider you intend to use.

How will your advisor calculate NAV per share?, page 6

 13. Please revise to clarify that the independent va luer will also value the liabilities.  Please
also provide more detailed disclosure of a ny adjustments the advisor might make to the
values calculated by th e independent valuer.
 Who should buy shares?, page 9

 14. We note that you refer to yourself as a finite -life entity.  However,  we note that you are
not required to liquidate by a specific date and that your board may determine when you
should commence a liquidity event.  Please revi se your disclosure to clarify this point.
 Will you use debt borrowing to finance your investments?, page 11

 15. Please revise to disclose the amount of leverage you are permitted to incur under your
charter.
 What are your exit strategies?, page 11

 16. We note your disclosure that you intend to begi n a liquidity event in three to six years
after the offering.  However, on page 114 and elsewhere, you state that you intend to
begin a liquidity event in six to eight y ears. Further, on page 130, you state that you
intend to begin a liquidity event in three to fi ve years.  Please revi se your disclosure as
appropriate to clarif y this discrepancy.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 4
 17. Please revise to disclose that your intended liquidity events are subject to the board
determining it is appropriate to commence a li quidity event and that  shareholders must
approve a proposed liquidity event.  Please revise to clarify, if true, that you may
continue indefinitely if your shareholde rs do not approve your proposed liquidity
transactions.
 What conflicts of interest will your advisor …?, page 12

 18. Please disclose the respective interest held  in your sponsor by Messrs. Schorsch and
Kahane.
 What are the fees that you will pay …?, page 14

19. Please clarify how your advisors and sub-adviso rs will be compensated if you enter into a
joint venture with an affiliate.
Selling Commissions, retail shares, page 15

 Platform Fee …, page 16

20. Please disclose the maximum platform fee to  be paid assuming you sell the total amount
of institutional shares being registered in th is offering.  Please make similar revisions in
the table on page 62 and in the table starting on page 84.
 Operating Expenses, page 19

 21. We note that you intend to reimburse your advisor for personnel costs.  Please
specifically state whether you w ill reimburse your advisor for th e salaries and benefits to
be paid to your named executive officers.  Please tell us what consideration you have
given to providing the disclosure requir ed by Item 402 of Regulation S-K regarding
compensation of your named executive officers.  Refer to Item 402(a)(2), which requires
disclosure of compensation paid “by any person for all services rendered in all capacities
to the registrant.”  Please make similar revi sions to your disclosure in the table starting on
page 84.
 Compensation and Restricted Stock Award s to Independent Directors, page 21

 22. We note your disclosure on page 70 regarding a per transaction fee that may be paid to
the directors.  Please provide disclosure regard ing this fee here and in the table starting on
page 84.
 Subordinated Distribution upon Termination of the Advisory Agreement, page 24

 23. Please revise to clarify how the amounts are determined.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 5
 Risk Factors, page 28

 It may be difficult to acc urately reflect…, page 32

 24. It appears that there may be material information known by the company regarding
changes in the NAV per share that may not be pr ovided to an investor prior to his or her
investment decision.  Please advise us why the company does not believe this creates a
significant liability issue.  Refer to Secti on 12(a)(2) and Rule 159 of the Securities Act.
 The management of multiple REITs…, page 34

 25. In this risk factor or the preceding risk factor, please identify the programs currently
publicly raising proceeds for investment a nd the aggregate dollar amount of securities
offered.
 We may not be able to sell our properties …, page 45

 26. We note your disclosure that “[m]any of [your ] leases will not contain rental increases
over time.”  However, on page 2, you indica te that your investme nt objective is “to
generate cash flow that will s upport a stable distribution to investors with potential for
growth through leases that link the rent to the change in the Cons umer Price Index, or
CPI, or other forms of lease increases.”  Pl ease revise you disclosure , as appropriate, to
address this discrepancy.
 Subordinated Participation in Net Sale Proceeds, page 84

 27. Please define the term “Net Sale Proceeds.”
 Valuation Policies, page 121

 28. Please provide a more detailed discussion of the process by which the advisor will
evaluate the independent valu er’s calculations and the ot her matters the advisor will
consider in making any adjustments.

Adverse Business Developments and Conditions, page 143

 29. Please provide more detail regarding the cumulative distributions and sources of
distributions of ARCT  since its inception.
 Plan of Distribution, page 199

 30. Please advise us whether the REIT intends to  conduct a follow-on offering.  If so, please
revise accordingly.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 6
 Subscription Process, page 204

 31. Please disclose whether a potential investor  can withdraw its subscription agreement
between the time of submission and time of accep tance.  Please also clarify whether the
purchase price is based on the NAV on the day of submission or acceptance.

Financial Statements and Notes

 Note 3 – Related Party Transacti ons and Arrangements, page F-10

 32. We note your advisor and its affiliates will receive compensation and reimbursement for
services relating to the offering and the inve stment and management of your assets.
Please expand your note disclosures to in clude significant terms relating to your
agreement with these entities.  Expanded disclosures should include information related to fees and compensation to be paid.

Table I, page A-2

 33. Please advise why the percentage leverage fo r ARC New York is ne gative.  In addition,
please confirm that the leverage ratios disclo sed in the footnotes ar e calculated in the
same manner as those in the table.

Table III: Operating Results of P ublic Program Properties, page A-10

34. We note footnote (5) of the table which states that Federal tax results for the year ended
December 31, 2010 are not available as of the da te of the filing.  Please advise us why
these are not available and revise to include  estimated information along with a footnote
noting the source of the data and whether the data is s ubject to adjustment.

Table V, page A-16
 35. Many of these properties appear to have been  purchased and sold at the same time.
Please advise.

Part II, page II-1

 Item 37. Undertakings, page II-3

 36. Please revise paragraph (A) clause (ii) to in clude the entire undert aking required by Item
512(a)(1)(ii) of Regulation S-K.

Exhibits

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 7
 37. Please file all required exhibits as promptly as  possible.  If you are not  in a position to file
your legal and tax opinions with the next am endment, please provide a draft copy for us
to review.

38. Please tell us why you are filing the “Form of ” various agreements.  Explain why you are
not able to file final, executed agreements  prior to effectiveness of the registration
statement.

39. We note that you filed an unexecuted versi on of your articles of amendment and
restatement as exhibit 3.1.  Please note that  the final executed version of this document
must be filed prior to effec tiveness.  Please refer to Item  601(b)(3) of Regulation S-K.
 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.
Notwithstanding our comments, 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.

Nicholas S. Schorsch
Chief Executive Officer and Chairman  American Realty Capital Global Daily Net Asset Value Trust, Inc. November 23, 2011 Page 8
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