Mail Stop 4631
                                                                 November 21,
2019


    Shy Datika
    President
    INX Limited
    Unit 1.02, 1st Floor 6 Bayside Road
    Gibraltar, GX11 1AA

           Re:    INX Limited
                  Amendment No. 3 to Registration Statement on Form F-1
                  Filed November 14, 2019
                  File No. 333-233363

    Dear Mr. Datika:

          We have reviewed your amended 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 registration statement and the
information you
    provide in response to these comments, we may have additional comments.
Unless we note
    otherwise, our references to prior comments are to comments in our November
8, 2019 letter.

    General

    1.     Please update disclosures in the prospectus to reflect recent
events, including, for
           example, disclosure regarding dilution, compensation and securities
ownership.

    The INX Token, page 9

    2.     We note your revision in response to comment 1 that you have no plan
to have the INX
           Token trade on a national securities exchange or any other exchange,
whether within or
           outside the United States. Please expand to disclose whether you
intend to list INX
           Tokens for trading on any platform, not limited to exchanges, in
jurisdictions within or
           outside the United States. Please make corresponding revisions on
page 30 and 120.
 Shy Datika
INX Limited
November 21, 2019
Page 2

Rights of INX Token Holders Upon an Insolvency Event, pages 13 and 106

3.     We note your revisions in response to comments 2 and 3. So that
investors will better
       understand the impact of the timing of an Insolvency Event on their
right to receive
       distributions of cumulative Adjusted Operating Cash Flow, please clarify
whether the
       right to the distribution vests upon the board's declaration of the
amount to be distributed,
       or upon March 31 regardless of the board's action. In either case,
please also clarify
       whether investors have any rights (contractual or otherwise) with
respect the amount of
       the distribution prior to vesting and, if not, what that means if an
Insolvency Event occurs
       before vesting. Finally, clarify whether you will announce fourth
quarter cumulative
       Adjusted Operating Cash Flow within 60 days after year-end, consistent
with other
       quarters.

Participation Right in Adjusted Operating Cash Flow, page 103

4.     We note your statement that you may withhold the distribution if payment
is prohibited
       by law pending proof of information reasonably necessary to ensure
compliance. Please
       clarify, if true, that this would include AML/KYC compliance, similar to
when you
       would freeze a wallet. Explain how the factors you would consider may
differ when
       determining whether to freeze a wallet or to withhold a distribution.

        You may contact Lory Empie, Staff Accountant, at (202) 551-3714 or
Stephen Kim,
Assistant Chief Accountant, at (202) 551-3291 if you have questions regarding
comments on the
financial statements and related matters. Please contact Christopher Dunham,
Staff Attorney, at
(202) 551-3783 or, in his absence, Pamela A. Long at (202) 551-3765 with any
other questions.


                                                             Sincerely,



                                                             Division of
Corporation Finance
                                                             Office of Finance