February 14, 2020

Robert Dechant
Chief Executive Officer
IBEX LIMITED
1700 Pennsylvania Avenue NW, Suite 560
Washington, DC 20006

       Re: IBEX LIMITED
           Amendment No. 1 to Draft Registration Statement on Form F-1
           Submitted January 31, 2020
           CIK: 0001720420

Dear Mr. Dechant:

      We have reviewed your amended draft 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 providing the requested information and
either submitting
an amended draft registration statement or publicly filing your registration
statement on
EDGAR. 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 the information you provide in response to these
comments and your
amended draft registration statement or filed registration statement, we may
have additional
comments. Unless we note otherwise, our references to prior comments are to
comments in our
January 16, 2020 letter.

Amendment No. 1 to Registration Statement on Form F-1

Prospectus Summary
Overview, page 1

1.     Your disclosure states that you have experienced above-average growth
rates in recent
       years. To provide context, please clarify what measure is growing and
what you are using
       as a comparison to conclude that the growth rate is above-average.
Capitalization, page 55

2.     We note your disclosure that your pro forma as adjusted basis gives
effect to the
       application of estimated net proceeds of the offering as described under
Use of Proceeds.
 Robert Dechant
IBEX LIMITED
February 14, 2020
Page 2
         However, your disclosure under Use of Proceeds indicates that you have
no binding
         obligations to enter into any of the acquisitions or investments that
you describe. Please
         clarify whether you intend to use proceeds to pay down your debt. If
so, please revise the
         Use of Proceeds disclosure to be consistent with the pro forma
disclosures presented in
         this table.
Management's Discussion and Analysis of Financial Condition and Results of
Operation
Overview
Overview, page 64

3.       We note your revised disclosure in response to prior comment 2. Please
further clarify
         how you define a high growth client, and whether your Velocity clients
are also Fortune
         500 companies. If not, please provide further context to the size of
these companies.
Consolidated Financial Statements
Notes to Financial Statements
19.5 Restricted Stock Award Program, page F-68

4.       Your response to prior comment 9 indicates that the fair value of the
Company's common
         shares used in the determination of the fair value of restricted
shares granted in the year
         ended June 30, 2019 was $0.61 per common share. Revise your Critical
Estimates and
         Judgments disclosures to describe the valuations methods used to
estimate the market
         value of shares of common stock. In this regard, the disclosure should
describe the
         methods utilized and explain why the valuation of your shares of
common stock are
         significantly below the valuation of your preferential shares.
Further, explain whether the
         methods employed will change as you approach the launching of your
IPO.
       You may contact Laura Veator, Staff Accountant, at (202) 551-3716 or
Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions
regarding
comments on the financial statements and related matters. Please contact
Matthew Derby, Staff
Attorney, at (202) 551-3334 or Kathleen Krebs, Special Counsel, at (202)
551-3350 with any
other questions.



FirstName LastNameRobert Dechant                              Sincerely,
Comapany NameIBEX LIMITED
                                                              Division of
Corporation Finance
February 14, 2020 Page 2                                      Office of
Technology
FirstName LastName