July 16, 2024

Thomas Kalmbach
Chief Financial Officer
Globe Life Inc.
3700 South Stonebridge Drive
McKinney, TX 75070

       Re: Globe Life Inc.
           Form 10-K for Fiscal Year Ended December 31, 2023
           Response Dated June 20, 2024
           File No. 001-08052
Dear Thomas Kalmbach:

       We have reviewed your June 20, 2024 response to our comment letter and
have the
following comments.

       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. Unless we
note otherwise, any references to prior comments are to comments in our June 6,
2024 letter.

Form 10-K for Fiscal Year Ended December 31, 2023
Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
21

1.     Please refer to prior comment 3. To the extent that lapse rate trends
materially impact
       revenue recognized or other relevant financial metrics, please revise
future filings to
       disclose the rates and discuss the trends. Refer to Item 303 of
Regulation S-K for
       guidance.
Other Receivables, page 67

2.     Please refer to prior comment 10. Please revise your proposed disclosure
in future filings
       to:

             Clarify what portion of commissions are considered level
commissions in the final
           sentence in the first paragraph of your proposed disclosure.
 July 16, 2024
Page 2

              Disclose an approximate percentage of commissions that are paid
in advance. We
            note the agent debit balance was $501 million at December 31, 2023
and total
            commissions earned during 2023 was approximately $1.1 billion.
Note 6 - Policy Liabilities, page 96

3.     Please refer to prior comment 13. We note your statement that any line
for derecognition
       will be $0. Please revise note (3) to your present value of expected
future policy benefits
       table in future filings to clarify that benefit payments do not include
lapses.
       Please contact Michael Volley at 202-551-3437 or Amit Pande at
202-551-3423 if you
have questions.



                                                            Sincerely,

                                                            Division of
Corporation Finance
                                                            Office of Finance