Morgan, Lewis & Bockius LLP                                         MORGAN LEWIS
1701 Market Street
Philadelphia,  PA  19103-2921
Tel: +1.215.963.5000
Fax: +1.215.963.5001
www.morganlewis.com


January  28,  2016

FILED  AS  EDGAR  CORRESPONDENCE

Keith Gregory
Lauren Hamilton
U.S. Securities and Exchange Commission
100 F Street, NE
Washington, D.C. 20549

Re:     Gallery Trust (File No. 333-208691)
        -----------------------------------

Dear Mr. Gregory and Ms. Hamilton:

On behalf of our client, Gallery Trust (the "Registrant"), this letter responds
to the comments you provided on behalf of the staff (the "Staff") of the
Securities and Exchange Commission (the "SEC"), regarding the Registrant's
registration statement on Form N-14 (the "Registration Statement"), filed on
December 22, 2015, with respect to the reorganization of The International
Equity Portfolio (the "Target Fund"), a series of Delaware Pooled Trust (the
"Target Trust"), into the Mondrian International Equity Fund (the "Acquiring
Fund"), a new series of the Registrant (the "Reorganization"). Below, we have
briefly summarized your comments and questions, followed by our responses based
on information provided by the Target Trust and Mondrian Investment Partners
Limited ("Mondrian"), the investment sub-adviser of the Target Fund and the
investment adviser of the Acquiring Fund. Capitalized terms not defined herein
should be given the meaning provided in the Registration Statement.

1.   COMMENT. Please provide an analysis of the factors considered in
     determining which Fund should be the accounting survivor in the
     Reorganization, as set forth by the Staff in North American Security Trust
     (pub. avail. Aug. 5, 1994) (the "NAST Letter").

     RESPONSE. In the NAST Letter, the Staff set forth certain factors that
     should be considered in determining whether a surviving fund may use the
     historical performance of one of several predecessor funds. The Staff
     stated that comparison should be made of the attributes of the surviving
     fund and the predecessor funds to determine which predecessor fund, if any,
     the surviving or new fund most closely resembles. The Staff noted that
     among the factors to be compared are the funds' investment advisers;
     expense structures and expense ratios; investment objectives, policies and
     restrictions; portfolio compositions; and asset sizes.



     Applying these factors, the Registrant notes that: (i) the investment
     sub-adviser of the Target Fund will be the investment adviser of the
     Acquiring Fund, and the portfolio managers of the Target Fund will manage
     the Acquiring Fund; (ii) the expense ratios of the Target Fund and the
     Acquiring Fund are expected to be substantially the same, although the
     Acquiring Fund has contractually agreed to limit expenses, and will impose
     a 2% redemption fee on shares held for less than 30 days; (iii) the Target
     Fund and the Acquiring Fund have substantially the same investment
     objective and substantially similar principal investment strategies, while
     any differences between the Funds' investment restrictions are not expected
     to materially impact the operations of the Funds; and (iv) the Acquiring
     Fund was newly created to acquire all of the assets and liabilities of the
     Target Fund, and, therefore, the Acquiring Fund will have the same
     portfolio and assets as the Target Fund.

     Accordingly, the Registrant believes that the Target Fund should be the
     accounting survivor in the Reorganization.

2.   COMMENT. Please include disclosure in the "Summary of Key Information" and
     "The Proposed Reorganization - Federal Income Tax Considerations" sections
     regarding the amount of capital loss carryforwards of the Target Fund as of
     its most recent financial statement date, and the limitations on the use of
     such capital loss carryforwards as a result of the Reorganization.

     RESPONSE. The Registrant respectfully declines to make the requested
     changes because the Reorganization is intended to be a tax-free
     reorganization pursuant to Section 368(a)(1)(F) of the Code, and,
     accordingly, the use of the Target Fund's capital loss carryforwards is not
     expected to be limited as a result of the Reorganization.

3.   COMMENT. If the Target Fund's portfolio is expected to be repositioned in
     connection with the Reorganization:

     (a) In the "Summary of Key Information" and "The Proposed Reorganization -
     Federal Income Tax Considerations" sections, please disclose the market
     value of the investments expected to be sold in connection with the
     Reorganization, and, if the capital gains associated with such investments
     exceed the Target Fund's capital loss carryforwards, please disclose the
     amount of such capital gains on an aggregate and per share basis; and

     (b) In the Capitalization table, include an adjustment reducing the Funds'
     combined net assets by the amount of brokerage or other transaction related
     costs expected to be incurred in connection with the Reorganization.

     RESPONSE. Mondrian confirms that it does not expect to reposition the
     Target Fund's portfolio in connection with the Reorganization.

4.   COMMENT. Please provide the Capitalization table information as of a date
     within 30 days of the effective date of the Registration Statement.

     RESPONSE. The requested change has been made.



5.   COMMENT. Please consider including a "President's Letter" as the initial
     or introductory document to the Proxy Statement/Prospectus (the "Proxy"),
     as permitted by General Instruction F to Form N-14.

     RESPONSE. The Registrant respectfully declines to make the requested change
     because a "President's Letter" is not required by Form N-14.

6.   COMMENT. Please include and/or update all missing or bracketed information
     in the Registration Statement, including the information with respect to
     the Target Fund's performance through December 31, 2015.

     RESPONSE. The requested changes have been made.

7.   COMMENT. If one Proxy will be delivered to two or more Target Fund
     shareholders who share an address in accordance with Section 14a-3(e)(1) of
     the Securities Exchange Act of 1934, as amended (the "Exchange Act"),
     please include the information required by Item 23 of Schedule 14A under
     the Exchange Act.

     RESPONSE. The Target Trust confirms that Target Fund shareholders of record
     who share an address will be provided with separate copies of the Proxy.

8.   COMMENT. On the proxy card, please (a) specify how proxy card instructions
     may be revoked, (b) disclose that the Meeting may be adjourned if
     sufficient votes to approve the Reorganization are not received by the date
     of the Meeting and (c) state how improperly marked proxy cards will be
     voted.

     RESPONSE. The Registrant respectfully declines to include the requested
     information on the proxy card, because it believes that information
     regarding revocation and adjournment need not be repeated from the Proxy,
     and, as discussed below, the Target Trust has confirmed that improperly
     marked proxy cards would be handled on a case-by- case basis.

9.   COMMENT. Please file signed agreements in response to Item 16 of Form
     N-14.

     RESPONSE. Signed agreements have been incorporated into the Registration
     Statement by reference to pre-effective amendment no. 3 to the Registrant's
     registration statement on Form N-1A (File No. 333-206713), filed with the
     SEC via EDGAR on January 27, 2016, Accession No. 0001135428-16-000984.



10.  COMMENT. In the Notice of Special Meeting of Shareholders of the Target
     Fund (the "Notice"), please (a) disclose that the Meeting may be adjourned
     if sufficient votes to approve the Reorganization are not received by the
     date of the Meeting, and (b) consider explaining how incorrectly marked
     proxy cards will be voted.

     RESPONSE. The Notice has been revised to state that the Meeting may be
     adjourned if sufficient votes to approve the Reorganization are not
     received by the date of the Meeting, but the Registrant respectfully
     declines to address how improperly marked proxy cards would be voted,
     because such determinations would be made on a case-by-case basis, taking
     into account the nature of the marking, the Target Trust's governing
     documents and Delaware law.

11.  COMMENT. Please address the internet availability of proxy materials, as
     required by Rule 14a-16 under the Exchange Act.

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because it believes that the Reorganization is a business
     combination transaction, to which the internet availability of proxy
     materials requirements do not apply, per Rule 14a-16(m).

12.  COMMENT. Please correct the punctuation in the sentence defining the term
     "Acquiring Fund" in the introduction to the Proxy.

     RESPONSE. The requested change has been made.

13.  COMMENT. In the introduction to the Proxy, in the answer to the question
     in the "Summary of Key Information" section of the Proxy regarding what
     will happen if shareholders of the Target Fund do not approve the
     Reorganization, and in the "The Proposed Reorganization - Summary of
     Agreement and Plan of Reorganization" section of the Proxy, please briefly
     describe the other courses of action for the Target Fund that the Target
     Fund Board will consider if shareholders of the Target Fund do not approve
     the Reorganization or the Reorganization does not close.

     RESPONSE. The Registrant respectfully declines to make the requested
     changes, because the Target Trust has confirmed that the Proxy accurately
     indicates that the Target Fund Board will consider other courses of action
     for the Target Fund if and when shareholders of the Target Fund do not
     approve the Reorganization or the Reorganization does not close.

14.  COMMENT. In the "Summary of Key Information" section of the Proxy, please
     consider including additional questions and answers regarding (a) the
     expected costs of the reorganization and the bearer of such costs, and (b)
     the proxy solicitor and the bearer of the proxy solicitation costs.

     RESPONSE. A question and answer have been added to the section to highlight
     that all the costs of the Reorganization will be borne by Mondrian or an
     affiliate. The Registrant believes, however, that information regarding the
     proxy solicitor is appropriately contained within the "Voting Information -
     Proxy Solicitation" section of the Proxy, and that disclosing the costs of
     the Reorganization would not assist investors in making an informed
     decision about whether to approve the Reorganization, because neither the
     Target Fund nor the Acquiring Fund would bear such costs.



15.  COMMENT. In the answer to the question in the "Summary of Key Information"
     section of the Proxy regarding the reasons for the proposed Reorganization,
     please consider (a) the appropriateness of the reference to future
     economies of scale, given the uncertainty as to whether they could be
     achieved, and (b) briefly describing the other factors that the Target Fund
     Board considered in concluding that the Reorganization would be in the best
     interest of the Target Fund and its shareholders.

     RESPONSE. The Registrant believes that the reference to future economies of
     scale is appropriate because the answer conveys the uncertainty as to
     whether they could be achieved. The Registrant also believes that the
     description of the other factors that the Target Fund Board considered in
     concluding that the Reorganization would be in the best interest of the
     Target Fund and its shareholders is appropriately contained within the "The
     Proposed Reorganization - Board Considerations in Approving the
     Reorganization" section of the Proxy.

16.  COMMENT. In the "Summary of Key Information" section of the Proxy, please
     state whether a shareholder would be subject to the Acquiring Fund's
     redemption fee if the shareholder redeems Acquiring Fund shares received in
     connection with the Reorganization within 30 days of purchasing the
     associated Target Fund shares.

     RESPONSE. The section has been revised to state that Acquiring Fund shares
     acquired in connection with the Reorganization will not be subject to the
     redemption fee.

17.  COMMENT. In the answer to the question in the "Summary of Key Information"
     section of the Proxy regarding how the Funds' investment objectives,
     principal investment strategies and principal risks compare:

     (a) Please clarify if the principal risks of the Funds differ as a result
     of the fact that the Target Fund may invest up to 30% of its net assets in
     securities of issuers in the commercial banking industry, while the
     Acquiring Fund may not do so;

     (b) Please disclose that investments in participatory notes are part of the
     Acquiring Fund's principal investment strategies, while the Target Fund
     does not invest in participatory notes; and

     (c) In light of the Acquiring Fund's ability to invest in participatory
     notes, please consider revising the statement that the principal investment
     strategies of the Acquiring Fund are substantially the same as the
     principal investment strategies of the Target Fund, and the statement that
     the principal risks of owning shares of the Acquiring Fund are the same as
     the principal risks of owning shares of the Target Fund, to state that the
     principal investment strategies and principal risks are "substantially
     similar." Please also use the "substantially similar" terminology in the
     statements in the "Additional Information about the Funds" section of the
     Proxy comparing the Funds' principal investment strategies and principal
     risks.

     RESPONSE. The requested changes have been made.



18.  COMMENT. In the answer to the question in the "Summary of Key Information"
     section of the Proxy regarding how the Funds' expenses compare:

     (a) Please address the Acquiring Fund's redemption fee in the narrative
     comparison;

     RESPONSE. The requested change has been made.

     (b) Please move the reference to footnote 1 to the fee table to the "Other
     Expenses" row, and move the reference to footnote 2 to the fee table to the
     "Less Fee Waiver and/or Expense Reimbursement" row; and

     RESPONSE. The requested change has been made.

     (c) In footnote 2 to the fee table, please disclose any recoupment
     provision in the expense limitation agreement.

     RESPONSE. The Registrant confirms that there is no recoupment provision in
     the expense limitation agreement.

19.  COMMENT. In the answer to the question in the "Summary of Key Information"
     section of the Proxy regarding how the Funds' performance records compare:

     (a) Please revise the statement that the Acquiring Fund has not yet
     commenced operations to state that the Acquiring Fund had not commenced
     operations prior to the Reorganization; and

     (b) Please replace the reference to the Target Fund in the statement that
     past performance is not necessarily an indication of how the Fund will
     perform in the future with a reference to the Acquiring Fund, because the
     future performance would be that of the Acquiring Fund if the
     Reorganization is consummated.

     RESPONSE. The Registrant respectfully declines to make the requested
     changes because the Proxy is designed to be utilized prior to the
     Reorganization. The answer has, however, been revised to clarify that the
     Target Fund's past performance is also not necessarily an indication of how
     the Acquiring Fund will perform in the future.

20.  COMMENT. Please review the answer to the question in the "Summary of Key
     Information" section of the Proxy regarding whether the Acquiring Fund will
     have different portfolio managers than the Target Fund, in light of the
     identification of Andrew Porter as a portfolio manager of the Target Fund,
     but not the Acquiring Fund.

     RESPONSE. The answer has been revised to state that, while the portfolio
     management team of the Acquiring Fund is substantially the same as the
     portfolio management team of the Target Fund, the Acquiring Fund has
     identified a smaller group of team members as being primarily responsible
     for the day-to-day management of the Acquiring Fund's portfolio.



21.  COMMENT. In the answer to the question in the "Summary of Key Information"
     section of the Proxy regarding how shareholders can vote on the
     Reorganization, please describe how shareholders can revoke proxy
     instructions.

     RESPONSE. The requested change has been made.

22.  COMMENT. In the answer to the question in the "Summary of Key Information"
     section of the Proxy regarding where shareholders can find more information
     about the Funds and the Reorganization, please consider indicating the
     times of day during which shareholders may call the proxy solicitor.

     RESPONSE. The portion of the answer regarding the proxy solicitor has been
     removed.

23.  COMMENT. Please describe the principal risks of investing in participatory
     notes in the "Additional Information about the Funds - Comparison of
     Principal Risks of Investing in the Funds" section of the Proxy.

     RESPONSE. The principal risks of investing in participatory notes are
     described in the "Derivatives Risk" paragraph in the section. In light of
     the foregoing, the Registrant believes that the section includes
     appropriate disclosure with respect to this matter.

24.  COMMENT. Please describe the Acquiring Fund's policy with respect to
     temporary defensive positions in the "Additional Information about the
     Funds - Comparison of Principal Investment Strategies" section of the
     Proxy, because the description of the Target Fund's principal investment
     strategies in the section references a temporary defensive approach.

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because the Target Fund's policy with respect to temporary
     defensive positions is not described in the section, and neither Fund
     considers temporary defensive positions to be part of its principal
     investment strategies.

25.  COMMENT. Please consider whether it is appropriate to state in the
     "Additional Information about the Funds - Comparison of Fundamental and
     Non-Fundamental Investment Restrictions" section of the Proxy that certain
     differences between the Funds' policies would never materially impact the
     operations of the Acquiring Fund.

     RESPONSE. The section indicates that the differences are not expected to
     materially impact the operations of the Acquiring Fund. In light of the
     foregoing, the Registrant believes that the section includes appropriate
     disclosure with respect to this matter.

26.  COMMENT. Please revise the Acquiring Fund's fundamental policy with
     respect to borrowing to incorporate the referenced provisions of the 1940
     Act.

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because, as noted in the Proxy, the Acquiring Fund has adopted
     fundamental policies that generally limit its investments only as required
     by the 1940 Act, the rules and regulations thereunder or any exemption
     therefrom, so as to avoid the need to seek shareholder approval to change a
     fundamental policy in connection with an amendment or new interpretation of
     such statute, rules or regulations. The Registrant notes that the Acquiring
     Fund's statement of additional information includes a description of the
     borrowing provisions of the 1940 Act.



27.  COMMENT. Please consider creating separate rows for the comparisons of the
     Funds' fundamental policies with respect to commodities and real estate in
     the "Additional Information about the Funds - Comparison of Fundamental and
     Non-Fundamental Investment Restrictions" section of the Proxy, given that
     the impact of the differences in the commodities policies is described
     separately from the impact of the differences in the real estate policies.

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because the presentation of the Acquiring Fund's fundamental policy
     with respect to commodities and real estate is consistent with the
     presentation of the policy in the Acquiring Fund's statement of additional
     information.

28.  COMMENT. In the "Additional Information about the Funds - Comparison of
     Shareholder Rights" section of the Proxy, please consider describing the
     circumstances under which shareholders of the Funds would be entitled to
     call shareholder meetings under the 1940 Act.

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because the section's description of the rights of shareholders to
     call meetings is consistent with the description of such rights in the
     Funds' governing instruments, shareholders of both Funds generally have the
     same rights with respect to calling shareholder meetings, and General
     Instruction F to Form N-1A states that "[d]escriptions of practices that
     are necessitated or otherwise affected by legal requirements should
     generally not include detailed discussions of the law."

29.  COMMENT. In the "The Proposed Reorganization - Summary of Agreement and
     Plan of Reorganization" section of the Proxy, please remove the statement
     that the summary is qualified by reference to the form of Agreement.

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because it believes that the summary can be qualified by reference
     to the form of Agreement.

30.  COMMENT. Please describe any material differences between the rights of
     Target Fund shareholders and the rights of Acquiring Fund shareholders, as
     required by Item 4(a)(5) of Form N-14.

     RESPONSE. The Registrant believes that the disclosure in the "Additional
     Information about the Funds - Comparison of Shareholder Rights" section of
     the Proxy meets the requirements of Item 4(a)(5) of Form N-14. In light of
     the foregoing, the Registrant believes that the Proxy includes appropriate
     disclosure with respect to this matter.



31.  COMMENT. In the "The Proposed Reorganization - Board Considerations in
     Approving the Reorganization" section of the Proxy:

     (a) In connection with Section 15(f) of the 1940 Act, please describe the
     terms of the referenced Transition and Support Services Agreement;

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because it does not believe that Section 15(f) requires disclosure
     of the terms of the Transition and Support Services Agreement. In addition,
     the Registrant notes that Section 15(f) is addressed in the "The Proposed
     Reorganization - Summary of Agreement and Plan of Reorganization" section
     of the Proxy.

     (b) Please explain supplementally why the fact that the portfolio managers
     who subadvise the Target Fund will serve as the portfolio managers of the
     Acquiring Fund was considered by the Target Fund Board in making its
     determination to approve the Agreement;

     RESPONSE. The Target Trust advises that the Target Fund Board considered
     portfolio management continuity as part of its overall consideration of the
     similarities between the Funds, which factored into its determination to
     approve the Agreement.

     (c) Please explain supplementally why the reasonableness of the terms and
     conditions of the Agreement was considered by the Target Fund Board in
     making its determination to approve the Agreement; and

     RESPONSE. The Target Trust advises that the Target Fund Board considered
     the reasonableness of the terms and conditions of the Agreement in making
     its determination to approve the Agreement, because the terms and
     conditions of the Agreement factored into its determinations that: (i)
     participation in the Reorganization was in the best interest of the Target
     Fund and its shareholders; and (ii) the interests of the Target Fund's
     shareholders would not be diluted as a result of the Reorganization.

     (d) Please disclose any other information and factors relevant to the
     Reorganization, including negative factors, that the Target Fund Board
     considered in making its determination to approve the Agreement.

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because the Target Trust has confirmed that it believes that the
     Proxy appropriately discloses the factors that the Target Fund Board
     considered in making its determination to approve the Agreement.

32.  COMMENT. In the "The Proposed Reorganization - Costs of the
     Reorganization" section of the Proxy, please consider explaining why an
     affiliate of Mondrian would bear the expenses of the Reorganization, and
     disclosing the identity of such affiliate.

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because it does not believe that information regarding the
     affiliate, or the reasons that the affiliate would bear the expenses of the
     Reorganization, would assist investors in making an informed decision about
     whether to approve the Reorganization.

33.  COMMENT. In the "Voting Information - Proxy Solicitation" section of the
     Proxy, please disclose how a telephonic proxy vote may be revoked.

     RESPONSE. The Registrant respectfully declines to make the requested
     change, because the revocation rights with respect to a telephonic proxy
     vote are the same as those with respect to a written proxy vote, and such
     rights are discussed elsewhere in the Proxy.

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

I hereby acknowledge on behalf of, and with the express authority granted by,
the Registrant that: (i) the Registrant is responsible for the adequacy and
accuracy of the disclosure in its registration statement; (ii) SEC Staff
comments or changes to disclosure in response to Staff comments in the
registration statement reviewed by the Staff do not foreclose the SEC from
taking any action with respect to the registration statement; and (iii) if, to
the Registrant's knowledge, an inquiry or investigation is currently pending or
threatened by the SEC and if the SEC subsequently, in order to protect its
investigative position, so requests, the Registrant will not assert SEC Staff
comments with respect to the inquiry or investigation as a defense in any
proceeding initiated by the SEC under the federal securities laws of the United
States.

As indicated in the SEC's June 24, 2004 release regarding the public release of
comment letters and responses, you are requesting such acknowledgements from all
companies whose filings are being reviewed and that this request and these
acknowledgements should not be construed as suggesting that there is an inquiry
or investigation or other matter involving the Registrant.

If you have any questions, need any additional information or would like any
clarification, please contact me at (215) 963-5620.

Very truly yours,

/s/ Leon Salkin
---------------
Leon  Salkin