SecProbe.io

CORRESP
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Mark Selinger

Tel 212.801.9221

Fax 212.801.6400

Mark.Selinger@gtlaw.com

May 1, 2023

U.S. Securities and Exchange Commission

Division of Corporation Finance

Office of Technology

100 F Street, N.E.

Washington, D.C. 20549

Attention: Mark Brunhofer

Sharon Blume

Eric Envall

Sonia Bednarowski

Re: INX Ltd.

Form 6-K

Filed November 15, 2022

File No. 000-56429

Dear Mr. Brunhofer:

On behalf of INX Ltd. (the
“Company” or “INX”), we are writing to submit the Company’s responses to the comments of the staff (the
“Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission (the “Commission,” or
the “SEC”) dated April 13, 2023, relating to the above referenced Form 6-K (File No. 000-56429) filed by the Company on November
15, 2022. Concurrently with the submission of this letter, the Company is filing its Annual Report on Form 20-F for the year ended December
31, 2022 (the “Annual Report on Form 20-F”). For ease of review, we have set forth below each of the numbered comments of
your letter and the Company’s responses thereto. Please note that as verbally agreed between Company counsel and the SEC, the Company’s
responses to questions 9 and 10 will be provided to the Staff in a supplemental response letter.

Greenberg Traurig, LLP | Attorneys at Law

One Vanderbilt Avenue | New York, New York 10017 | T +1 212.801.9200 | F +1 212.801.6400

Albany. Amsterdam. Atlanta. Austin. Berlin¬. Boston. Charlotte. Chicago. Dallas. Delaware. Denver. Fort Lauderdale. Houston. Las Vegas. London*. Long Island. Los Angeles. Mexico City+. Miami. Milan». Minneapolis. New Jersey. New York. Northern Virginia. Orange County. Orlando. Philadelphia. Phoenix. Portland. Sacramento. Salt Lake City. San Diego. San Francisco. Seoul∞. Shanghai. Silicon Valley. Singapore⁼. Tallahassee. Tampa. Tel Aviv^. Tokyo¤. Warsaw~. Washington, D.C. West Palm Beach. Westchester County.

Operates as: ¬Greenberg
Traurig Germany, LLP; *A separate UK registered legal entity; +Greenberg Traurig, S.C.; »Greenberg Traurig
Santa Maria; ∞Greenberg Traurig LLP Foreign Legal Consultant Office; ⁼Greenberg Traurig Singapore LLP;
^A branch of Greenberg Traurig, P.A., Florida, USA; ¤GT Tokyo Horitsu Jimusho and Greenberg Traurig Gaikokuhojimubegoshi Jimusho;
~Greenberg Traurig Nowakowska-Zimoch Wysokiński sp.k.

www.gtlaw.com

U.S. Securities and Exchange Commission

May 1, 2023

Page 2

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.

Response:

The Company respectfully advises
the Staff that it intends to include the following table of all the crypto assets and security tokens that the Company offers on INX Trading
Solutions, also known as INX.One, in its Annual Report on Form 20-F, under “Item 4. History and Development of the Company”:

    INX Digital

    INX Securities

    BTC

    INX

    ETH

    MSTO

    ZEC

    BCAP

    LTC

    Spice

    USDC

    PRTS

    AVAXC

    SCI2

    LINK

    TXC

    MATIC

    TRZX

    FTM

    ATX

    UNI

    TRUCPAL

    CRV

    XMNA

    AAVE

On the INX Digital platform,
the digital assets are offered in the following 43 U.S. jurisdictions, plus Washington D.C. and Puerto Rico, as well as in foreign
jurisdictions that we believe we have the right to operate in: Alabama, Alaska, Arizona, Arkansas, California, Colorado, Connecticut,
Delaware, District of Columbia, Florida, Georgia, Idaho, Illinois, Indiana, Iowa, Kansas, Kentucky, Louisiana, Maine, Maryland, Massachusetts,
Michigan, Minnesota, Mississippi, Missouri, Montana, Nebraska, New Hampshire, New Jersey, New Mexico, North Carolina, North Dakota, Oklahoma,
Oregon, Pennsylvania, Puerto Rico, Rhode Island, South Carolina, South Dakota, Utah, Vermont, Washington, West Virginia, Wisconsin, and
Wyoming.  For these assets, the Company offers listing and trading services.

On the INX Securities platform, the
security tokens are listed for trading in all 50 U.S. states, as well as in foreign jurisdictions that we believe we have the right to
operate in. For these security tokens, in addition to listing and trading services, the Company also offers placement agent
services.

Greenberg Traurig, LLP | Attorneys at Law

www.gtlaw.com

U.S. Securities and Exchange Commission

May 1, 2023

Page 3

 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 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.

Response:

The Company respectfully advises
the Staff that it intends to include the following revised risk factor in its Annual Report on Form 20-F:

If the Company fails
to properly characterize a digital asset listed for trading under applicable securities laws, it may be subject to regulatory scrutiny,
inquiries, investigations, fines, and other penalties, which may adversely affect the business, operating results, and its financial condition.

The SEC and its staff have
taken the position that many digital assets fall within the definition of a “security” under the U.S. federal securities laws.
The SEC has stated that the characterization of a digital asset as a security or non-security should be made by application of the Howey test,
which provides a multi-factor analysis for determining whether a digital asset is a security, as well as other case law and reports, orders
and statements issued by the SEC which provide guidance on when a digital asset should be treated as a security for purposes of US federal
securities laws.

Several foreign jurisdictions
have taken a broad-based approach to classifying crypto assets as “securities,” while other foreign jurisdictions, such as
Switzerland, Malta, and Singapore, have adopted a narrower approach. As a result, certain crypto assets may be deemed to be a “security”
under the laws of some jurisdictions but not others. Various foreign jurisdictions may, in the future, adopt additional laws, regulations,
or directives that affect the characterization of crypto assets as “securities.”

The classification of a crypto
asset as a security under applicable law has wide-ranging implications for the regulatory obligations that flow from the offer, sale,
trading, and clearing of such assets. For example, a crypto asset that is a security in the United States may generally only be offered
or sold in the United States pursuant to a registration statement filed with the SEC or in an offering that qualifies for an exemption
from registration.

The Company has developed specific
criteria and follows its policies and procedures to analyze  whether a digital asset could be deemed a “security” under
applicable laws prior to listing such asset on the INXD trading platform. The Company’s policies and procedures do not constitute
a legal standard, but rather represent the Company-developed model, which it uses to make a risk-based assessment regarding the likelihood
that a particular crypto asset could be deemed a “security” under applicable laws. Regardless of the conclusions, the Company
could be subject to legal or regulatory action in the event the SEC, a state or foreign regulatory authority, or a court were to determine
that a supported crypto asset currently traded on our INXD platform is a “security” under applicable laws.

Greenberg Traurig, LLP | Attorneys at Law

www.gtlaw.com

U.S. Securities and Exchange Commission

May 1, 2023

Page 4

The policy reviews a variety
of factors for each listing, including applying such review as it relates to the Howey test. The policy considers, among other things,
the use, purpose, and specific features of each crypto asset being considered. Once all of these assessments are completed and internally
approved by the relevant members of Company management, the assessment is reviewed and approved by the INXD Board of Directors.

The Company will only approve
a listing that it reasonably determines is not used to circumvent laws and regulations or that may facilitate the obfuscation or concealment
of a customer’s or counterparty’s identity. Additionally, the Company will only approve cryptocurrencies that it reasonably
determines, using the above-described procedures, are not crypto assets that fall under the jurisdiction of securities regulations in
the U.S. and may seek the guidance of outside legal counsel in this determination. The Company will only permit the trading of a crypto
asset consistent with relevant consumer protection standards and that do not jeopardize INXD’s safety and soundness as a going concern.

The Company believes that its
process reflects a comprehensive and thoughtful analysis and is reasonably designed to facilitate consistent application of available
legal guidance. However, it recognizes that the application of securities laws to the specific facts and circumstances of crypto assets
may be complex, and that a listing determination does not guarantee any conclusion under the U.S. federal securities laws.

There can be no assurances
that we will properly characterize any given crypto asset as a security or non-security for purposes of determining whether our platform
will support trading of the crypto asset, or that the SEC, foreign regulatory authority, or a court, if the question was presented to
it, would agree with our assessment. If an applicable regulatory authority or a court, having final determinative authority on the subject,
were to determine that a supported crypto asset currently offered, sold, or traded on our INXD platform is a security, we could be subject
to judicial or administrative sanctions for failing to offer or sell the crypto asset in compliance with the registration or exemption
requirements. Such an action could result in injunctions, cease and desist orders, as well as civil monetary penalties, fines, and disgorgement,
criminal liability, and reputational harm. Customers that traded such supported crypto assets on our platform and suffered trading losses
could also seek to rescind a transaction that we facilitated on the basis that it was conducted in violation of applicable law, which
could subject us to significant liability. We may also be required to cease facilitating transactions in the supported crypto asset other
than via our licensed subsidiaries, which could negatively impact our business, operating results, and financial condition. Furthermore,
if we remove any crypto assets from trading on our platform for any reason, our decision may be unpopular with users and may reduce our
ability to attract and retain customers, especially if such assets remain traded on unregulated exchanges, which includes many of our
competitors.

Further, if Bitcoin, Ethereum,
or any other supported crypto asset is deemed to be a security under any U.S. federal, state, or foreign jurisdiction, or in a proceeding
in a court of law or otherwise, it may have adverse consequences for such supported crypto asset. For instance, all transactions in such
supported crypto assets would have to be registered with the SEC or other foreign authority, or conducted in accordance with an exemption
from registration, which could severely limit its liquidity, usability and transactability. Moreover, the networks on which such supported
crypto assets are utilized may be required to be regulated as securities intermediaries, and subject to applicable rules, which could
effectively render the network impracticable for its existing purposes. Further, it could draw negative publicity and a decline in the
general acceptance of the crypto asset. Also, it may make it difficult for such supported crypto assets to be traded, cleared, and held
in custody as compared to other crypto assets that are not considered to be securities.

Adding crypto assets to, or
removing from our platform

The Company has a policy and process
in place for adding new crypto asset securities and cryptocurrencies for listing or trading on its platform. The Company’s legal
and compliance teams, in cooperation with the Chief Compliance Officer, evaluate the legal, compliance, technology, cybersecurity, and
operational risks with respect to listing a cryptocurrency. The evaluation is done in the form of a due diligence checklist, upon which
the above parties have to signify approval, and once this is done, the checklist is then sent to the Board of Directors of INXD, for a
final review and approval.

More specifically, the relevant
risk areas that INXD takes into consideration regarding each cryptocurrency include the overview and history, roadmap, business purpose,
usage, distribution and concentration, regulation, compliance obligations, Howey Test triggers, risk assessment, token type, white paper,
blockchain type, engineering, security and code, prototype, consensus process, network, operating costs, supply, rewards and penalties,
development team, and operations.

Adding the Millennium Sapphire,
Compound and Aave Tokens to our platform

Regarding the listing of the Millennium
Sapphire Security Token (“MSTO”) to our ATS for trading, MSTO first signed a listing agreement with INX and provided due diligence
items requested by the Company, pursuant to INXS’ listing policy. Following review of all relevant documents submitted, INXS verified
that the primary offering was done in compliance with the exemptions for registration under Regulation D and Regulation S of the Securities
Act of 1933 which are specifically noted in the INXS Membership Agreement as valid primary exemptions for which INXS can provide secondary
market trading services. INXS reviews and signs off on all due diligence and listing agreements, including those of MSTO. As part of additional
due diligence, and since neither INXS, nor any of its affiliated entities, minted the security tokens, INXS integrated the ATS settlement
flow with MSTO’s ownership record holder (the “Digital Registrar”). A Digital Registrar maintains books and records
for security token issuers similar to the functions of a transfer agent in the United States. Once this integration was tested and implemented,
the security token was made available for trading on the ATS.

Regarding the addition of the
Compound and Aave tokens to our crypto asset trading platform, the Company respectfully advises the Staff that it followed the same procedures
described in the response to comment 3 above in determining to add these tokens to our trading platform.

Greenberg Traurig, LLP | Attorneys at Law

www.gtlaw.com

U.S. Securities and Exchange Commission

May 1, 2023

Page 5

 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.

Response:

The Company respectfully advises
the Staff that it intends to include the following disclosure in its Annual Report on Form 20-F, u