Mail Stop 4631
                                                               August 18, 2020


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

           Re:    INX Limited
                  Amendment No. 10 to Registration Statement on Form F-1
                  Filed August 12, 2020
                  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 August
10, 2020 letter.

    Prospectus Summary, page 1

    1.     Please add a section to your Prospectus Summary listing the states
in which you expect to
           be qualified to offer and sell INX Tokens at the commencement of the
offering, as well as
           the states in which purchasers will be qualified to resell their INX
Tokens. Please also
           disclose whether you will expand your offering to additional states
after effectiveness,
           and whether you need to maintain any state registrations of INX
Tokens in order for
           purchasers to resell their INX Tokens, including your obligation or
intention to do so.
           Please further outline the suitability standards which may or may
not apply, either to
           purchasers in your offering or in the secondary market, based on an
investor   s state of
           residence and address the impact of the aforementioned issues on the
liquidity for INX
           Tokens. Please make conforming revisions on pages 34 and 119, as
applicable.
 Shy Datika
INX Limited
August 18, 2020
Page 2

The Offering

Rights of INX Token Holders Upon an Insolvency Event, page 13

2.     Please prominently disclose that INX Token holders do not have a
perfected security
       interest in either the Cash Fund, or their Pro Rata Portion of the
Distributable Amount of
       your Cumulative Adjusted Operating Cash Flow. As such, please further
disclose that
       there is no guarantee that an INX Token holder will receive any funds
whatsoever
       following an Insolvency Event. Please make corresponding revisions on
pages 33 and
       107.

Management   s Discussion and Analysis of Financial Condition and Results of
Operations

Comparison of the Fiscal Years Ended December 31, 2019 and 2018

Financial liabilities at fair value through profit or loss - INX Token
liability, page 48

3.     Please revise your disclosure to clearly indicate that the $1.2 million
valuation of the
       tokens for your 18.8 million tokens is a value significantly less
($0.06/token) than the
       offering price of $0.90 per token. Your revised disclosure should bridge
the gap between
       the different valuations and how both valuations were determined.

        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