Mail Stop 4631
                                                               February 6, 2020


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

           Re:    INX Limited
                  Amendment No. 6 to Registration Statement on Form F-1
                  Filed January 17, 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 January
10, 2020 letter.

    Prospectus Summary

    Industry Overview

    Background & Current Market

    Markets for Blockchain Assets and ICOs, page 4

    1.     We note your revision regarding the continued downward trend for
ICOs in 2019. Please
           update footnote 4 here and footnote 12 on page 54 to support the
$3.2 billion estimate. In
           this regard, we note that information on the CoinSchedule website
suggests that ICOs
           raised only $1.4 billion in 2019.
 Shy Datika
INX Limited
February 6, 2020
Page 2

Use of Proceeds, page 39

2.     Revise this section and the table to disclose net proceeds based on your
minimum
       offering amount (i.e. gross proceeds of $5 million). Clearly state your
assumptions with
       respect to potential payments to A-Labs. Further, it is not clear that
you have or will
       have at the time of the offering the cash on hand necessary to cover
offering expenses.
       Please clarify that if you only raise the minimum gross proceeds of $5
million, the
       aggregate expenses of the offering will exceed the proceeds raised,
resulting in a net
       negative amount.

Dilution, page 43

3.     We note your revision in response to comment 7. Please correct and
explain to us your
       calculation of the total consideration and average price per INX Token
for the
       commitments to issue 1,348,929 INX Tokens. Your prospectus should also
disclose the
       consideration paid by, and the calculation for number of tokens to be
issued to, Mr.
       Alelov, Mr. Benish, Mr. Rafeli and Mr. Trister. Please further revise
your dilution table
       to include the 4,559,821 INX Tokens that will be issuable upon exercise
of options six
       months following the effective date of your registration statement, as
well as the 14,000
       INX Tokens issuable per month upon the exercise of options six months
following the
       effective date of your registration statement, or disclose your basis
for excluding these
       tokens and quantify the additional dilutive impact to new investors if
such tokens are
       issued. In this regard we note that the options will be exercisable
during your maximum
       offering period at an average price that is materially less than the
average price of your
       other commitments to issue INX Tokens included in the table.

Certain Relationships and Related Party Transactions

Agreements with Other Interested Parties, page 90

4.     We note you deleted disclosure related to A-Labs' "Second SAFE" on pages
90-91 and
       II-2, as well as this previously executed agreement dated August 30,
2019 from your
       Exhibit Index, whereas other references on pages 90 and 91 continue to
refer to A-Labs'
       "Second SAFE." Please revise to clarify this apparent discrepancy and,
if the Second
       SAFEs issued to either A-Labs and Michepro Holding Limited were canceled
or similar,
       as it appears, disclose all material facts related to such transactions.

Technical Features of the INX Token, page 99

5.     We note your response to comment 1 0. Please revise the disclosure on
page 100 to
       briefly summarize TokenSoft's role in reviewing and responding to
questions from
       Quantstamp during the audit of the INX Token smart contract, as well as
in designing
       your token issuance platform to be used in this offering, including the
scope of such
       design responsibilities. Please also correct the hyperlink in your
exhibit index.
 Shy Datika
INX Limited
February 6, 2020
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