Mail Stop 4561
                                                            March 9, 2018

Alex Mardikian
Chief Executive Officer
OBITX, Inc.
4720 Salisbury Road
Jacksonville, FL 32256

       Re:    OBITX, Inc.
              Registration Statement on Form S-1
              Filed February 9, 2018
              File No. 333-222978

Dear Mr. Mardikian:

       We have reviewed your 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.

Cover Page

1.     Please revise to clarify whether you are offering warrants to purchase 3
million shares of
       common stock or the 3 million shares of common stock underlying the
warrants. While
       your cover page and risk factor on page 22 indicates that you are
registering warrants,
       your disclosure on page 14 indicates that you are registering the
underlying shares.

2.     You state that OBITX will be an "independent, publicly-traded" company
following the
       spin-off. Given that there is no public market for the company's stock,
please revise the
       disclosure that characterizes the company as publicly-traded. Further,
provide
       appropriate context regarding the statement that the company is
independent. In this
       regard, we note that Mr. Rosenberg, one of your two directors, is the
chief executive
       officer of MCIG, and that MCIG will hold approximately 95% of the voting
power of the
       outstanding capital stock by virtue of its continued ownership of the
Series A Preferred
       Stock.
 Alex Mardikian
OBITX, Inc.
March 9, 2018
Page 2

3.     Please disclose the fixed price, or price range, at which the selling
shareholders are
       offering their securities pursuant to Item 501(b)(3) of Regulation S-K.
In this regard, we
       note that there currently is no public market for your common stock but
that you plan to
       seek quotation on the OTC Bulletin Board or one of the premium
marketplaces of OTC
       Link ATS (i.e., OTCQX or OTCQB). As such, you may disclose that the
selling
       shareholders will sell at a fixed price, or range, per share until your
common stock is
       quoted on one of these markets and thereafter at prevailing market
prices or privately
       negotiated prices.

Risk Factors, page 17

4.     Update your discussion of the regulatory risks related to your digital
assets businesses.

5.     On page 13, you state that your products "will provide your consumers in
.. . . the
       cannabis markets with an advertising and marketing approach uniquely
designed for
       them." Please add a risk factor that describes the risks and
consequences under federal
       laws of engaging in business with cannabis markets.

6.     Please confirm that you intend to file a Form 8-A to register your
common stock under
       Section 12 of the Securities Exchange Act of 1934. If not, provide a
risk factor that
       clarifies your reporting obligations if you are only subject to the
reporting obligations
       imposed by Section 15(d) of the Exchange Act. To this end, explain the
effect on
       investors of the automatic suspension under Section 15(d) of the
Exchange Act, as well
       as the inapplicability of the proxy rules and Section 16 of the Exchange
Act.

"We will have broad discretion over the use of the net proceeds . . . ," page
22

7.     You disclose that you will receive net proceeds from this offering. We
note, however,
       that the selling shareholders will receive all the proceeds from this
offering, as stated in
       the Use of Proceeds section. Please revise your disclosure to eliminate
the implication
       that the potential sale of 3,000,000 shares of common stock pursuant to
the exercise of
       the outstanding warrants is part of this offering.

Business, page 39

8.     As your proposed business plan may involve acquiring, holding and
selling securities, it
       appears that these activities may implicate obligations under the
federal securities laws,
       including, but not limited to, any requirements to register as a
broker-dealer under the
       Securities Exchange Act of 1934 or an investment company under the
Investment
       Company Act of 1940. Please explain how you intend to conduct your
operations in
       accordance with these requirements.

9.     Your description of "Blockchain Network" on page 7 seems limited to one
type of
       blockchain network rather than an expansive discussion of the various
types of
 Alex Mardikian
OBITX, Inc.
March 9, 2018
Page 3

       blockchain networks. Please either expand your discussion on page 42 or
limit your
       definition of "Blockchain Network" on page 7 to conform to the
discussion. Describe the
       "other strategic opportunities" in digital assets and blockchain
technologies you intend to
       pursue.

10.    We note you refer to various dates of incorporation throughout your Form
S-1 including
       March 13, March 30 and April 3, 2017. We also note the consent of your
independent
       auditor, filed as Exhibit 23, refers to an inception date of March 10,
2017 while page F-4
       indicates a March 13, 2017 inception date. Please revise to clarify the
company's actual
       dates of incorporation and inception throughout the filing. In addition,
revise to indicate
       the specific period reported in your financial statements and related
disclosures for
       operations, stockholders' equity and cash flows.

11.    Since the OBITX, Inc. historical costs of doing business as a "spin-off"
entity from
       MCIG, Inc. may not be indicative of expected future results and trends
please revise to
       include unaudited pro forma financial information reflecting the impact
of this
       transaction. Refer to Rule 11-01(a)(7) of Regulation S-X.

12.    Please disclose whether you have entered into any agreements with MCIG,
Inc., such as a
       separation agreement or transition services agreement, that will govern
the relationship
       between you and MCIG after the spin-off. If you have executed such
agreements, file
       them as exhibits to the registration statement pursuant to Item
601(b)(10) of Regulation
       S-K. To the extent no such agreements exist, please address any material
risks to your
       business in the prospectus summary and a risk factor.

Management's Discussion and Analysis of Financial Condition and Results of
Operations

Plan of Operations, page 45

13.    We note that you use the terms "Digital Assets" and "cryptocurrency."
Please explain
       what you mean by these terms and clarify that not all digital assets are
"currencies" and
       may be securities or other types of assets. Identify the specific
digital assets or
       "cryptocurrency" you currently hold and that you intend to acquire, hold
and trade.

14.    Please identify the trading platforms or exchanges you intend to trade
these assets on and
       disclose whether they are registered national securities exchanges or
alternative trading
       systems. Please also disclose what you mean by "initial bounty
offerings."

15.    We note you have generated substantially all your revenue through sales
of your
       marketing and consulting services to the "Digital Asset industry."
Describe the services
       you have provided and clarify how you were compensated for them.
Disclose whether
       you currently hold any digital assets.
 Alex Mardikian
OBITX, Inc.
March 9, 2018
Page 4

16.   With respect to your disclosure regarding the Uses of Cryptocurrencies on
page 42, we
      note your expansive description of entities that are accepting
cryptocurrencies. Provide
      the basis for these statements and note, if true, that other market
participants, such as
      credit card companies and certain financial institutions are not
accepting such digital
      assets.

17.   Please describe the investment strategy/methodology you will follow to
make digital
      asset purchases and build your portfolio. Disclose whether you intend to
acquire
      securities in registered or unregistered offerings and how you will
determine whether you
      can transfer or sell acquired assets. Discuss how your strategy may be
impacted by the
      potential illiquidity and volatility of digital assets. Explain how you
will value the
      digital assets you hold given their volatility and fragmentation,
potential for
      manipulation, and general lack of regulation of underlying digital assets
markets.
      Describe your intended custodial practices for the digital assets and the
cybersecurity
      measures you intend to use to protect them.

18.   You indicate that you will compete with entities that have greater
hashing capacity.
      Discuss whether you intend to acquire digital assets through mining and,
if so, specify the
      digital assets that you will mine and describe the unique characteristics
of each type of
      mining, including the extent to which mining servers and associated
equipment will be
      allocated to one digital asset versus another. Provide a detailed
discussion of the steps
      you will take to launch your mining operations and describe how you will
fund those
      operations.

19.   We note your near-term goals include "expansion of [y]our Digital Assets"
and "further
      expansion into the cryptocurrency markets." Please provide an enhanced
discussion of
      your plan of operations for the next 12 months. Describe the anticipated
milestones with
      regard to the development and commercialization of your existing products
and services
      as well as the creation of a portfolio of digital assets. Further,
disclose how much
      additional capital you need to accomplish each goal; how you plan to
raise that capital;
      and how you will prioritize the allocation of capital.

Executive Compensation, page 50

20.   Please explain how the $42,000 paid to Mr. Markidian for the period ended
October 31,
      2017, was determined. We note your disclosures indicate that it may have
derived from a
      consulting agreement. Refer to Item 402(o) of Regulation S-K.
 Alex Mardikian
OBITX, Inc.
March 9, 2018
Page 5

Selling Shareholders, page 52

21.    Your tabular disclosure indicates that the total number of Resale Shares
being registered
       is 600,000, whereas your disclosure otherwise indicates that you are
registering
       5,500,000 of such shares, including 2,500,000 outstanding shares of
common stock and
       3,000,000 shares underlying outstanding warrants. Please reconcile.
Further, you should
       provide footnote disclosure that identifies the nature of any position,
office, or other
       material relationship that any of the selling shareholders have had with
you since
       inception. Refer to Item 508 of Regulation S-K.

Index to Financial Statements, page 55

22.    Tell us why you have not provided audited financial statements from the
period of
       inception through fiscal year end April 30, 2017 separately from the
financial information
       for the period ended October 31, 2017.

Report of the Independent Registered Public Accounting Firm, page F-2

23.    Explain the Company's considerations to select an auditor based in
Israel for the audit.
       In this regard, we note the Company's offices are in Jacksonville,
Florida.

Statements of Operations, page F-3

24.    We note that you present a gross profit measure that excludes
depreciation and
       amortization expense. Please tell us how you considered the guidance in
SAB Topic
       11.B with regard to your presentation of depreciation and amortization
that is directly
       attributable to the cost of sales. In this regard, if you do not
allocate any depreciation and
       amortization to cost of sales, you should remove the gross profit
subtotal from your
       statements of operations and re-label the cost of sales line item
throughout the filing to
       indicate that it excludes depreciation and amortization. MD&A should be
revised to
       reflect the impact of any reclassification in your financial statements.

Note 1. Organization and Basis of Presentation, page F-6

25.    Please tell us whether your historical financial information reflects
certain expenses
       incurred by your parent company, MCIG, Inc., on your behalf. If so,
please revise to
       disclose this information. Refer to SAB Topic 1B.

26.    Please clarify how you comply with the guidance in ASC 605 regarding
your revenue
       recognition policies for each of your software and services products and
solutions.
       Further, revise to state the date you expect to adopt ASC 606 and any
potential impact
       from adoption, if known. Refer to SAB Topic 11M.
 Alex Mardikian
OBITX, Inc.
March 9, 2018
Page 6

27.    You appear to include two, duplicative disclosures related to
concentration of credit risk,
       one on page F-7 and one on page F-10. Please revise accordingly.

28.    In your disclosure related to concentration of credit risk and
significant customers on
       page F-7, you state that one primary customer accounted for 99% of
revenues and 100%
       of accounts receivable as of October 31, 2017. However, you also state
that you have
       limited concentration of credit risk because of the diverse group of
customers you
       provide services to. Please revise to reconcile these two statements.

        We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence of
action by the staff.

       Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

        You may contact Brittany Ebbertt, Staff Accountant, at (202) 551-3572
or Craig Wilson,
Senior Assistant Chief Accountant, at (202) 551-3226 if you have questions
regarding comments
on the financial statements and related matters. Please contact Bernard Nolan,
Attorney-Adviser,
at (202) 551-6515 or, in his absence, me at (202) 551-3453 with any other
questions. If you
require further assistance, you may contact Barbara C. Jacobs, Assistant
Director, at (202) 551-
3735.

                                                            Sincerely,

                                                            /s/ Jan Woo

                                                            Jan Woo
                                                            Legal Branch Chief
                                                            Office of
Information
                                                            Technologies and
Services

cc:    Thomas G. Amon
       Law Office of Thomas G. Amon