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CORRESP
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ENDEXX
CORPORATION

38246
North Hazelwood Circle

Cave
Creek, Arizona 853311749

480-595-6900

July
14, 2023

Via
EDGAR

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

Washington,
D.C. 20549

Attn:
Keira Nakada

  Re:
  Endexx Corporation

  Form
10-K for the Fiscal Year Ended September 30, 2022

  Filed
January 13, 2023

  File
No. 000-30233

Ladies
and Gentlemen:

Endexx
Corporation (the “Company”) is submitting this letter in response to the comment letter from the staff (the “Staff”)
of the Securities and Exchange Commission (the “Commission”) dated May 8, 2023 (the “Comment Letter”), with respect
to the Company’s Annual Report on Form 10-K for its fiscal year ended September 30, 2022. Prior to the date of this letter, on
June 9, 2023, the Company filed an amended Annual Report (the “Amended 10-K”) for that fiscal year and, concurrently, telephonically
advised Staff of that filing.

For
the ease of Staff, the comments from the Comment Letter have been transcribed and the Company’s responses are set forth immediately
following the comments.

Form
10-K for the Fiscal Year Ended September 30, 2022

Item
9a. Controls and Procedures, page 30

    1.
    Please
    disclose the conclusions of your principal executive officer and principal financial officer regarding the effectiveness of your
    disclosure controls and procedures and internal controls over financial reporting as of the end of the period covered by this report.
    Refer to Items 307 and 308(a)(3) of Regulation S-K. This comment also applies to your Form 10-Q for the quarterly period ended December
    31, 2022.

Response:

In
both the Amended 10-K and the subsequent Form 10-Q, the Company disclosed the conclusions of its principal executive officer and principal
financial officer regarding the effectiveness of its disclosure controls and procedures and internal controls over financial reporting
as of the end of the periods covered by each of the reports.

Item
15. Exhibits and Financial Statement Schedules, page 47

    2.
    We
    did not see Inline XBRL provided in connection with this filing. Please advise or revise as necessary. Refer to Item 601(b)(101)
    of Regulation S-K.

Response:

The
Company provided Inline XBRL in connection with its Amended 10-K filing.

United
States Securities and Exchange Commission

Division
of Corporation Finance

Office
of Trade & Services

Attn:
Keira Nakada

July
14, 2023

Page
2

Item
8. Financial Statements and Supplementary Data, page F-1

    3.
    It
    appears that your financial statements are presented without an audit opinion. Please confirm that your financial statements were
    audited by an independent accountant. In addition, please amend your filing to include a report from your independent registered
    public accountant that covers the two fiscal years presented herein. Refer to Rules 2-02 and 8-02 of Regulation S-X.

Response:

The
Company’s financial statements that were included in the Amended 10-K were audited by an independent accountant. The Amended 10-K
included an audit opinion and a report by an independent registered public accountant that covered the Company’s two fiscal years
that were presented in the Amended 10-K.

If
Staff should have any further questions or comments regarding this issue, please feel free to contact the undersigned or Randolf W. Katz
at 949-697-3103.

Thank
you for your ongoing courtesy and assistance in this matter.

Very
truly yours,

    ENDEXX CORPORATION

    By:
    /s/
    Todd Davis

    Todd
    Davis

    Chief
    Executive Officer