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                             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.
 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.



FirstName LastNameLawrence S. Elbaum, Esq.                    Sincerely,
Comapany NameVinson & Elkins LLP
                                                              Division of
Corporation Finance
December 12, 2022 Page 2                                      Office of Mergers
and Acquisitions
FirstName LastName