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                               April 13, 2023

       Shy Datika
       Chief Executive Officer
       INX Ltd
       Unit 1.02, 1st Floor
       6 Bayside Road
       Gibraltar, GX11 1AA

                                                        Re: INX Ltd
                                                            Form 6-K
                                                            Response Dated
February 21, 2023
                                                            File No. 000-56429

       Dear Shy Datika:

              We have reviewed your February 21, 2023 response to our comment
letter 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 these comments within ten business days by
providing the requested
       information or advise us as soon as possible when you will respond. If
you do not believe our
       comments apply to your facts and circumstances, please tell us why in
your response.

            After reviewing your response to these comments, we may have
additional
       comments. Unless we note otherwise, our references to prior comments are
to comments in our
       December 21, 2022 letter.

       Current Report on Form 6-K filed November 15, 2022

       General

   1.                                                   We note your response
to comment 1. Please augment your disclosure in this area
                                                        by providing to us and
include in future filings a table of all of the crypto assets and
                                                        security tokens you
offer services in on INX.One, or elsewhere in your corporate
                                                        structure. Also note in
this disclosure, the services you offer for each crypto asset or
                                                        security token, as well
as each jurisdiction where such services are offered.
   2.                                                   Refer to your response
to comment 3. Please revise the risk factor in your response
                                                        letter to remove the
statements that the legal test for determining whether any given crypto
                                                        assets may "evolve over
time" and that the SEC's views in this area have "evolved over
 Shy Datika
FirstName
INX Ltd LastNameShy Datika
Comapany
April       NameINX Ltd
       13, 2023
April 213, 2023 Page 2
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FirstName LastName
         time" and continue to evolve. Please remove these statements as the
legal tests are well
         established by U.S. Supreme Court case law and staff have issued
reports, orders, and
         statements that provide guidance on when a crypto asset may be a
security for purposes of
         the U.S. federal securities laws.
3.       Refer to your response to comment 8. In future filings, please
disclose the material terms
         of your agreement with BitGo for acting as the custodian of your
client's crypto assets and
         your own crypto assets, including a description of BitGo's insurance
and the degree to
         which BitGo's insurance provides coverage for the loss of your
client's crypto assets and
         your crypto assets. In addition, please add risk factor disclosure
regarding the risks of
         holding all of your client's crypto assets and your crypto assets in
hot wallets.
4.       Refer to your response to comment 23. In future filings, please expand
the disclosure in
         the risk factors to identify specific pending material crypto asset
legislation or regulation
         in the jurisdictions in which you offer your services and products.
5.       Refer to your response to comment 25. In future filings, please
identify the partnering
         banks that hold your customers' funds.
6.       Refer to your response to comment 26. In future filings, please
provide quantitative
         information regarding the price volatility of crypto assets.
7.       Refer to your response to comment 29. Please revise the disclosure in
future filings to
         provide risk factor disclosure that your INX Digital trading platform
may be operating as
         an unregistered exchange, unregistered broker-dealer or unregistered
clearing agency in
         the United States, and discuss the potential consequences associated
with those risks. In
         this regard, we note your response that INXD is licensed to operate as
a money transmitter
         in 43 U.S. states plus Washington D.C. and Puerto Rico and that INXS
is registered as a
         broker-dealer in United States.

Exhibit 99.1: Unaudited Consolidated Interim Financial Statements for the
period ended
September 30, 2022
Notes to Condensed Consolidated Interim Financial Statements
Note 2: Significant Accounting Policies
h. Digital Assets, page F-16

8.       We acknowledge your response to the second bullet to prior comment 32.
Please
         represent to us that in your upcoming 2022 Form 20-F you will revise
your disclosure to
         clarify that you no longer carry digital asset as indefinite-lived
intangible assets with the
         advent of your trading platform. Otherwise tell us why this disclosure
is not meaningful
         to an investor's understanding to your current operations.
9.       We acknowledge the response to the fourth bullet of prior comment 32
and your statement
         that the principal market or most advantageous market for your digital
assets held is
         frequently not known or determinable and your reference to the
provision in IFRS 13.17
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FirstName
INX Ltd LastNameShy Datika
Comapany
April       NameINX Ltd
       13, 2023
April 313, 2023 Page 3
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         that an entity need not undertake an exhaustive search of all possible
markets to identify
         the principal or most advantageous market. Please address the
following and reference
         the authoritative literature you rely upon to support your position:
             Tell us how an aggregated price from multiple exchanges and
platforms on
              coinmarketcap.com can represent the price from a single market
contemplated in
              IFRS 13.16.
             Tell us how you considered the second sentence in IFRS 13.17 that
the market in
              which you normally transact for each digital asset is presumed to
be your principal or
              most advantageous market.
             Tell us whether you identify a principal or most advantageous
market for each digital
              asset you hold and separately determine that the difference
between the prices in
              these markets and on coinmarketcap.com at each reporting period
are immaterial. To
              the extent that you do not make this assessment each reporting
period and rely on
              your belief that any difference would be immaterial, tell us how
you do not have a
              significant deficiency or material weakness in internal controls
over financial
              reporting given the requirement to identify a single principal or
most advantageous
              market for each digital asset held.
i. Revenue recognition, page F-17

10.      We acknowledge your response to prior comment 33. Please provide us
with the
         following additional information as it relates to Sales of Digital
Assets by Customers.
             Explain the differences between a market, limit or stop order
trade type. Provide us
              with separate, step by step examples, of each type of sale
transaction including a
              description of how the sold crypto moves from one customer wallet
to another.
             For trade types that are not executed immediately, explain why and
tell us when
              customer accounts are updated to reflect sales of crypto.
             Provide us a complete accounting analysis with citations to the
authoritative literature
              that supports your determination that the company does not
control the
              cryptocurrency being provided before it is transferred to the
buyer. Refer to
              paragraph 33 of IFRS 15.
             In Section 3.4 of the INX Digital User Agreement, you indicate
that    INX Digital
              may use shared Digital Currency wallets, controlled by INX
Digital or an INX
              Custodial Partner. INX Digital may commingle users    Digital
Currencies.
                o   Explain how frequently you use shared Digital Currency
wallets and which
                    trade types they are used for.
                o   Include how you considered the commingling of users'
Digital Currencies
                    in shared Digital Currency wallets, controlled by INX
Digital or an INX
                    Custodial Partner, in the accounting analysis requested
above.
             In Section 4.2 of the INX Digital User Agreement you indicate for
sales transactions,
                 to secure the performance of your obligations under this
Agreement, you may be
              required to grant to INX Digital or one of the INX Custodial
Partners a lien on and
              security interest in and to the balances in your INX Digital
Account.
                o   Provide us an example of a trade with INX Digital or one of
the INX Custodial
 Shy Datika
INX Ltd
April 13, 2023
Page 4

                 Partners that would require a customer to grant a lien on its
INX Digital
                 Account and the purpose of such lien. We note the statement in
your response
                 that    the customer must have sufficient buying power
(sufficient USD or
                 relevant digital assets balance in the account) for the order
to be executed.    Tell
                 us whether the company provides any liquidity support to its
customers for
                 digital asset sales transactions.
            o    Include how you considered any company provided liquidity
support in the
                 accounting analysis requested above.

Exhibit 99.2: Management's Discussion and Analysis of Financial Condition and
Results of
Operations
Operational Highlights, page 15

11.   We acknowledge your response to prior comment 31. Please confirm that you
will
      provide the disclosures referred to in your response in your upcoming
Form 20-F.
      Otherwise explain to us how these disclosures would not be meaningful to
an investor's
      understanding of your results of operations over time notwithstanding
your indication that
      your revenues have not been significant in the past.
        You may contact Mark Brunhofer at (202) 551-3638 or Sharon Blume at
(202) 551-
3474 if you have questions regarding comments on the financial statements and
related
matters. Please contact Eric Envall at (202) 551-3234 or Sonia Bednarowski at
(202) 551-
3666 with any other questions.



                                                              Sincerely,
FirstName LastNameShy Datika
                                                              Division of
Corporation Finance
Comapany NameINX Ltd
                                                              Office of Crypto
Assets
April 13, 2023 Page 4
cc:       Mark Selinger
FirstName LastName