Mail Stop 4631
                                                               October 22, 2019


    Shy Datika
    President
    INX Limited
    57/63 Line Wall Road
    Gibraltar, GX11 1AA
    Gibraltar

           Re:    INX Limited
                  Amendment No. 1 to Registration Statement on Form F-1
                  Filed September 26, 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
September 12, 2019 letter.

    General

    1. We note that the INX Digital and INX Services portals will be separate
and distinct trading
       platforms for cryptocurrencies and security tokens, respectively, and
that they will not
       support cross-asset trading. We also note your definitions of
"cryptocurrency" and "security
       token" on page 4 of the prospectus. Please disclose how you will
determine whether a
       blockchain asset is a cryptocurrency or a security token for purposes of
eligibility on the
       respective platforms.

    2. We note your risk factor on page 33 regarding the rights of INX Token
holders in the event
       of liquidation, insolvency, etc., as well as the Memorandum of Advice of
Hassans
       International Law firm, which states that the rights granted in favor of
INX Token holders
       upon liquidation would be enforceable by INX Token holders as unsecured
creditors of the
 Shy Datika
INX Limited
October 22, 2019
Page 2

    company and rank pari passu with other unsecured creditors of the company.
Please revise
    your disclosure on page 33 and elsewhere in your prospectus, such as in
your "Description of
    INX Tokens" section, to clearly identify the other interests that are, or
may be, senior to INX
    Tokens as well as other interests that are, or may be, pari passu with
respect to any claims by
    INX Token holders. In this disclosure, address claims to the Cash Fund and
distributions of
    Adjusting Operating Cash Flow (both declared and undeclared). In your
revisions, please
    also specifically identify where the 21% of shareholders that did not agree
to the
    subordination agreement rank in relation to INX token holders.

3. Please clearly and concisely describe the Adjusted Operating Cash Flow
distribution.
   Among other things, the description should address:

             Which holders will be entitled to the distribution (i.e., holders
as of which date).

             The form of payment.

             The factors the board will consider when deciding whether to pay
the distribution on
             an annual or quarterly basis.

             That calculations used to determine any quarterly distributions
will be made based
             on unaudited information.

             Whether the board has discretion to not pay an annual
distribution. If the board has
             discretion, describe the factors it will consider when making such
a determination
             and the situations in which the board would elect to not pay a
distribution. Include
             risk factor disclosure as well.

4. We note your disclosure on page 101 that you will publicly display the
number of INX
   Tokens that are eligible to receive the pro rata distribution on your
website and that this
   information will be updated daily. Given the importance of the Adjusted
Operating Cash
   Flow calculation to an investment decision, please describe how you plan to
update and
   convey this information to all INX Token holders throughout the year.

Cover Page

5. Please disclose your cumulative Adjusted Operating Cash Flow deficit and
explain that no
   distribution will be made, if at all, until you generate positive Adjusted
Operating Cash Flow
   that exceeds this deficit.

Prospectus Summary

Markets for Blockchain Assets and ICOs, page 4

6. Here and in the "Business" section, please delete the phrase regarding
treatment as a
   cryptocurrency from your description of the TurnKey Jet no action letter.
 Shy Datika
INX Limited
October 22, 2019
Page 3


Risk Factors

Our decision to reverse or suspend promotional incentives for the . . . , page
31

7. Please delete the second paragraph, as this mitigates the information
disclosed in the
   remainder of the risk factor. Please also revise the third paragraph so that
your ability to
   impact the trading price of INX Tokens is described less categorically. For
example, it may
   be more appropriate so say that you "may" be able to impact the trading
price.

Management's Discussion and Analysis of Financial Condition and Results of
Operations, page
45

8. We note your revision in response to comment 13. Please include this
information in
   MD&A.

Description of INX Tokens

Technical Features of the INX Token, page 97

9. Please revise to clarify whether you will make pro rata distribution
payments to holders of
   tokens in frozen wallets.

10. We note your response to comment 15 and disclosure that you expect to make
the results of
    the Hosho audit public once it has been completed. Please update this
disclosure to reflect
    that the audit has been completed, and summarize the material conclusions
and
    recommendations of the audit, as well as any resolutions thereof. Please
also revise to
    include Hosho's consent to the inclusion of the audit as an exhibit to the
registration
    statement and reference to the firm and audit in the prospectus, pursuant
to Securities Act
    Rule 436(a).

Participation Right in Adjusted Operating Cash Flow, page 101

11. Consistent with your response to comment 14, please revise to state that
the general public
    "will not" be able to independently verify the number of outstanding tokens
for purposes of
    their participation right in your Cumulative Adjusted Operating Cash Flow.
Please make
    corresponding revisions to your risk factor on page 32 discussing the
calculation and
    payment of distributions to token holders.

12. Please revise to clarify the impact, if any, of tokens in frozen wallets on
the calculation of
    your adjusted operating cash flow and your obligations to make pro rata
distribution
    payments to holders of tokens in frozen wallets.
 Shy Datika
INX Limited
October 22, 2019
Page 4

13. In this section and elsewhere, please revise to state that neither the
calculation of the
    cumulative Adjusted Operating Cash Flow nor any pro rata distributions
thereof will be
    audited at the time of any distribution.

Exhibits

14. Please revise Section 8.3 of Exhibit 4.1 to explicitly clarify whether the
exclusive forum
    provision applies to claims made under the federal securities laws. Please
make
    corresponding revisions to the prospectus, including the risk factor on
page 35.

15. Please have McDermott revise its legality opinion to clarify that the
purchase agreements,
    which describe rights of token holders, will be valid and legally binding
obligations of the
    company and enforceable against the company in accordance with its terms.
Please also
    include the opinions of McDermott and Hassans with the filed registration
statement.

        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