Mail Stop 4631
                                                                November 8,
2019


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

           Re:    INX Limited
                  Amendment No. 2 to Registration Statement on Form F-1
                  Filed October 29, 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 October
22, 2019 letter.

    General

    1.     We note that INX Tokens will be regulated as securities for purposes
of U.S. law. Please
           explain how INX Tokens will be regulated in foreign jurisdictions,
in particular in foreign
           jurisdictions where you conducted the Original Token Issuance.
Further, please explain
           your intentions with respect to the liquidity and trading of INX
Tokens sold offshore in
           the Original Token Issuance. In this regard, please explain whether
you intend to list
           INX Tokens for trading in jurisdictions other than the United States
and, if so, how such
           listings would comply with applicable U.S. securities laws. We note
that your current
           disclosure only addresses your intentions with respect to national
securities exchanges
           and ATSs.
 Shy Datika
INX Limited
November 8, 2019
Page 2

Prospectus Summary

The Offering

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

2.     We note that the Adjusted Operating Cash Flow distribution is a
contractual right but its
       calculation is not self-executing and the board is required to make the
distribution after
       approving the Company's financial statements and calculating the
distribution. As
       requested in prior comment 2 regarding claims of INX Token holders in
the event of
       liquidation, insolvency, etc., please discuss claims of INX Token holder
to both declared
       and undeclared distributions of Adjusted Operating Cash Flow. For
example, clarify
       whether the ranking of an INX Token holder's right to a distribution of
Adjusted
       Operating Cash Flow depends on whether a distribution has or has not yet
been declared.
       Also as requested in prior comment 2, please make revisions here and on
page 33 that
       correspond to disclosure on page 104 that "INX Token holders will be
unsecured
       creditors of the Company and would therefore rank pari passu with all
the other
       unsecured creditors of the Company."

Participation Right in Adjusted Operating Cash Flow, page 101

3.     We note your revision in response to comment 4 on page 103 that you will
provide
       quarterly calculations of your cumulative Adjusted Operating Cash Flow
that will be
       based on your unaudited consolidated quarterly financial statements.
Given the
       importance of this calculation to an investment decision, please revise
to disclose the
       schedule or dates by which you will provide such calculations on Form
6-K. In addition,
       please update your filing to provide the cumulative Adjusted Operating
Cash Flow
       calculation as of September 30, 2019.

4.     We note your revision in response to comment 9 regarding the payment of
distributions
       to holders of tokens in frozen wallets. Please disclose the material
terms of how you will
       "set aside the funds" due to INX Token holders, and how you will
determine when "such
       payments may be in violation of the terms and conditions of the INX
Token Purchase
       Agreement or applicable law." Your disclosures should clearly explain
the basis upon
       which you would withhold distribution payments, how you would hold and
release the
       funds, and what discretion you would use in the process, given your
disclosures that the
       distribution is the contractual obligation of the company and that the
board is required to
       make the distribution.
 Shy Datika
INX Limited
November 8, 2019
Page 3

        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