United States securities and exchange commission logo June 25, 2020 Richard Byworth Principal Executive Officer Diginex Ltd 35/F Two International Finance Street, Central Re: Diginex Ltd Post-effective Amendment No. 1 to Form S-4 Filed June 12, 2020 File No. 333-234147 Dear Mr. Byworth: We have reviewed your post-effective amendment and have the following comment. In our comment, 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 comment applies 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 this comment, we may have additional comments. Post-effective Amendment No. 1 to Form S-4, filed June 12, 2020 General 1. We note that you include audited financial statements for 8i Enterprises Acquisition Corp, as of July 31, 2019 and 2018, and unaudited interim financial statements as of January 31, 2020. However, it appears that 8i Enterprises Acquisition Corp. filed on June 12, 2020, a Form 10-Q for the period ended April 30, 2020. Please update your post-effective amendment to include the interim financial statements and related disclosures for 8i Enterprises Acquisition Corp. as of April 30, 2020. See the Instruction to Item 14 of Form F-4, Item 8.A.5. of Form 20-F, and Item 3-12(a) of Regulation S-X. Richard Byworth FirstName LastNameRichard Byworth Diginex Ltd Comapany NameDiginex Ltd June 25, 2020 Page 2 June 25, 2020 Page 2 FirstName LastName We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff. Please contact Katherine Bagley at (202) 551-2545 or Lilyanna Peyser at (202) 551- 3222 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services