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 30th Letter”). For convenience of reference, the Staff’s comment contained in the April 30th 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 | |