Mail Stop 4561
                                                             May 4, 2018


Michael Blum
Chief Financial Officer
ICOX Innovations, Inc.
4101 Redwood Ave., Building F
Los Angeles, CA 90066

       Re:    ICOX Innovations, Inc.
              Registration Statement on Form S-1
              Filed April 5, 2018
              File No. 333-224161

Dear Mr. Blum:

       We have reviewed your 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.

General

1.     We note you are in part registering the resale of shares of common stock
whose issuance
       is contingent on receiving conditional approval for the listing of your
common stock on a
       Canadian stock exchange. As the shares of common stock underlying the
subscription
       receipts were not outstanding as of the date that the registration
statement was filed,
       please provide us an analysis as to why you believe that these shares
can be registered at
       this time. For guidance, refer to Question 139.06 of our Compliance and
Disclosure
       Interpretations of Securities Act Sections.

2.     Please disclose the terms of the conditional approval for the listing of
the shares of the
       common stock on a Canadian stock exchange.
 Michael Blum
ICOX Innovations, Inc.
May 4, 2018
Page 2

3.     You state that you "may" accept tokens or coins as payment for your
services. It appears,
       however, that you will accept such form of payment pursuant to your
business services
       agreement with WENN Digital Inc. In this regard, we note your disclosure
that you have
       earned 20,000,000 "Platform tokens or coins." Please provide a detailed
analysis
       explaining whether you believe these tokens or coins should be
registered or exempt from
       registration under the Securities Act of 1933.

4.     To the extent that you believe that the tokens or coins are securities
and should be
       registered under the Securities Act of 1933, please disclose how you
will ensure that you
       are not deemed an investment company pursuant to Section 3(a)(1)(C) of
the Investment
       Company Act of 1940. Expand your disclosure to briefly discuss the
nature and impact
       of that provision of the Investment Company Act. We note your disclosure
in the first
       risk factor on page 9 that you believe you "will conduct [y]our business
in a manner that
       does not result in [you] being characterized as an investment company .
.. . or a broker-
       dealer." With regard to the latter, we also note your disclaimers on
pages 48 and 49.

Prospectus Cover Page

5.     You disclose that selling stockholders will sell their securities at
fixed prices, prevailing
       market prices, varying prices, or negotiated prices. We note, however,
that there
       currently is no existing market for your common stock. Please disclose
the fixed price at
       which the selling stockholders are offering their securities pursuant to
Item 501(b)(3) of
       Regulation S-K.

Prospectus Summary, page 3

6.     We note that you use the terms "cryptocurrency" and "digital asset."
Please clarify that
       not all digital assets qualify as a currency and may be securities or
other types of assets.
       In this regard, we note your disclosure in the first risk factor on page
8.

Risk Factors, page 4

7.     Your disclosure on page 60 indicates that Mr. Blum serves as an officer
of Hedgeye Risk
       Management, Seven7, LLC, and Asia Leisure Capital SA. In a risk factor,
please
       disclose the number of hours per week that he devotes to your
operations. Also address
       the limitations on the time and attention that he is able to devote to
the company, any
       potential conflicts of interest faced by him as a result of such
activity, and any procedures
       for addressing potential conflicts of interest.
 Michael Blum
ICOX Innovations, Inc.
May 4, 2018
Page 3

General Cryptocurrency Risks

"Regulatory changes or actions may alter the nature of an investment in us . .
.. ," page 5

8.     You state that you "do not participate in ICOs." Please qualify this
statement by
       explaining that you may receive a portion of the tokens or coins issued
by your customers
       in initial coin offerings as payment for your services, as disclosed on
page 47. Please
       also disclose this information in the prospectus summary.

Risks Related to Our Business

"We are currently dependent on one client," page 11

9.     We note that the one client from which you derived all your revenue in
fiscal year 2017
       was WENN Digital Inc., a related party. Please clarify that you are
dependent on
       transactions with related parties here and in the prospectus summary.

Description of Business, page 47

10.    Please provide a more detailed discussion of your business plans to
provide services for
       initial coin offerings. Discuss the material costs that you expect to
incur, known
       operational risks and challenges, and the timing of when you will be
able to provide all of
       the services described in the prospectus. We note that as of April 5,
2018, the company
       had no employees.

Initial Coin Offerings and Cryptocurrency, page 47

11.    Please identify the regulated exchanges to which you refer and on which
you intend to
       trade the cryptocurrencies that you will hold. Clarify whether you are
referring to trading
       platforms that are registered as national securities exchanges or
alternative trading
       systems under Section 6 and Section 15 of the Exchange Act,
respectively.

Corporate Governance

Director Independence, page 68

12.    You disclose that Mr. Chell qualifies as an independent director
pursuant to the definition
       of independence under the Nasdaq corporate governance rules. We note,
however, that
       Mr. Chell served as your president and chief executive officer until
October 15, 2017,
       holds 18.7% of your issued and outstanding shares of common stock, and
serves as an
       officer of Business Instincts Group Inc. and WENN Digital Inc. In light
of these
       circumstances, please provide the basis for your determination that Mr.
Chell is an
       independent director. Your response should include an explanation of his
role as
       "Chairman" of your company and, despite the "non-executive"
qualification, whether
 Michael Blum
ICOX Innovations, Inc.
May 4, 2018
Page 4

       such role involves performing policy making functions. Refer to Rule
3b-7 of the
       Exchange Act. To the extent Mr. Chell is not an independent director,
please add a risk
       factor that addresses the risk that is inherent in 75% of your board
being non-
       independent.


        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.

        Refer to Rule 461 regarding requests for acceleration. Please allow
adequate time for us
to review any amendment prior to the requested effective date of the
registration statement.

       Please contact Bernard Nolan, Attorney-Adviser, at (202) 551-6516 or me
at (202) 551-
3453 with any questions. If you require additional assistance, you may contact
Barbara C.
Jacobs, Assistant Director, at (202) 551-3730.

                                                            Sincerely,

                                                            /s/ Jan Woo

                                                            Jan Woo
                                                            Legal Branch Chief
                                                            Office of
Information
                                                            Technologies and
Services

cc:    Virgil Z Hlus
       Clark Wilson LLP