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CORRESP
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Mark Selinger

Tel 212.801.9221

Fax 212.801.6400

Mark.Selinger@gtlaw.com

May 12, 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 two remaining comments (comment
9 and 10) 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. For ease of review, we have set forth below each of the numbered comments of your letter and
the Company’s responses thereto.

    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 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.

Response: In response to the Staff’s
comment, to clarify the original response, the Company respectfully notes that the principal or most advantageous market is identified
for each digital asset held, as required under IFRS 13.16. In addition, the Company utilizes Coinmarketcap.com pricing as a
reference due to the fragmentation and the lack of regulations for digital asset markets, as discussed below, and a comparison of the
prices between the principal market and  Coinmarketcap.com is undertaken to determine whether any significant difference in
price for each digital asset exists and whether any unusual abnormalities exist within prices obtained from the principal market.

No such significant differences
existed at September 30 and December 31, 2022.

Additionally, the Company
has reassessed the related footnote wording as to the basis used to determine the fair value for digital assets and in the annual 2022
consolidated financial statements included our Form 20-F the wording has been revised to state that the fair value of digital assets is
based on quoted prices in the principal market as of 12:00 AM UTC.

The principal market is defined
by the Company in accordance with IFRS 13, or in the absence of a principal market, the most advantageous market.

Considerations for utilizing Coinmarketcap.com
as a “safety net” price check on principal market

When fair value measurement
was first used, the methodology was quite clear. Assets trading in a market would be valued by the closing price in the market at the
measurement date. At the time, most equities were traded on a single trading platform and thus left little ambiguity as to the market
price. Today, in cryptocurrency markets, we once again face a situation where the existing fair value guidelines may no longer reflect
market realities. In particular, the principal trading platform and most advantageous markets are difficult to establish in fragmented,
globally dispersed and unregulated markets.

One of the key characteristics
of the cryptocurrency market is its high level of fragmentation. The main cryptocurrencies, Bitcoin and Ethereum, are traded on over 100
trading platforms worldwide, with a large variety of underlying pricing mechanisms. Accordingly, in many cases, there may be no single
trading platform that is dominant in terms of volume, price discovery, or any other attribute that would make it an obvious principal
market. Moreover, either due to the difference in trading rules, and/or the lack of active liquidity providers at the current phase of
market development for many trading platforms, there can be significant differences in the prices between trading platforms, and due to
geographic disparity, a constant shift in the volume prominence throughout the day. Several other exchange-traded assets have either a
designated principal exchange or a de facto principal exchange that dominates all other exchanges in terms of volume or visibility and
serves as a focal point in the price discovery process. The situation is quite different for cryptocurrency where there may not exist
a single dominant market in terms of volume.

It is also important that
we ensure that the pricing data extracted from the designated principal market is as reliable as possible. Due to the rapid shifts in
trading volume noted earlier and the fact that some trading platforms lack proper oversight or are unregulated, the pricing data reported
may not be highly reliable. Under the current conditions, it is challenging to assume that this certainty exists and can be relied upon.

We have considered all factors
described above, which led to the utilization of Coinmarketcap.com as a “safety net” reference price for digital assets we
hold.

    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.

Response:

The below listed order types are available for
customers of INX to sell or buy a digital asset. Descriptions below describe differences between the order types as they relate to sales
of digital assets by customers:

    Market order – the sell order is executed immediately at the best bid price available in the orderbook at the time order is placed by the customer given the Spend amount (quantity to be sold) specified by the customer. Upon the execution of the order, the quantity of the asset sold is automatically deducted by the trading system from the seller’s account and the amount of consideration received is added in the currency specified within the order based on the execution price.

    2

  Limit order – the sell order is executed
at Limit bid price specified by the customer or higher available in the orderbook. The order is executed at the time when Limit price
or higher bid price is available in the order book. The sale is not guaranteed and the order may be pending for execution until the specified
Limit price is available. The order can be cancelled by the customer at any time. Upon the execution of the order, the quantity of the
asset sold is automatically deducted by the trading system from the seller’s account and the amount of consideration received is
added in the currency specified within the order based on the execution price.

  Stop limit order - the sell order is pre-set
by the customer and is placed automatically in the market once the best bid price reaches the Trigger Price. The order is executed at
Limit Price or higher available in the orderbook. Both the Limit Price and Trigger Price are pre-specified by the customer. The order
is executed at the time when Limit price or higher bid price is available in the order book. The sale is not guaranteed and the order
may be pending for execution until the specified Limit price is available. The order can be cancelled by the customer at any time. Upon
the execution of the order, the quantity of the asset sold is automatically deducted by the trading system from the seller’s account
and the amount of consideration received is added in the currency specified within the order based on the execution price.

  Stop market order - the sell order is pre-set by the customer and is
placed automatically in the market once the best bid price reaches the Trigger Price. It is executed at Market Price (best bid) available
in the orderbook in the quantity spefified (Spend amount). The Trigger Price is pre-specified by the customer. The order is executed immediately
after Trigger Price is reached. The sale is not guaranteed and the order may be pending for execution until the specified Trigger Price
is reached. The order can be cancelled by the customer at any time. Upon the execution of the order, the quantity of the asset sold is
automatically deducted by the trading system from the seller’s account and the amount of consideration received is added in the
currency specified within the order based on the execution price.

    3

Although limit orders, stop
limit and stop market orders may remain open pending execution until such time that the limit Price or the Trigger Price reaches the specified
level (set by a customer), under all order types, immediately after the sale order is executed, the quantity of the sold asset is automatically
deducted from the account balance of the seller and added to the account balance of the buyer, and the consideration received is simultaneously
added to the account balance of the seller and deducted from the account balance of the buyer. This process is automatically triggered
upon execution and there is no delay in reflecting the executed trade in each customer account. Buy and sell transactions are registered
within the internal Company’s system, but there is no actual movement of the assets on blockchain nor between wallets or bank accounts
as both the buyers’ and sellers’ digital assets and fiat are held in omnibus custodial accounts. A buy or a sell is a ledger
entry only transaction.

    ●
    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.

Response:

Principal versus agent

Judgment is required in determining
whether the Company is a principal or an agent in transactions between customers. The Company
evaluates the presentation of revenue on a gross or net basis based on whether it controls the cryptocurrency provided before it is transferred
to the customer (gross) or whether it acts as an agent by fulfilling its performance obligation by matching a trade and arranging for
other customers on the platform to provide the cryptocurrency to the customer (net).

The Company wishes to note
that activity of two subsidiaries are relevant to this evaluation and are separately considered while evaluating the activity and the
performance obligation: INX Digital, Inc. (“INX Digital”) and INX Solutions Limited (“INX Solutions”). We focus
our response below on INX Digital, and additionally include relevant information regarding recently launched activity under INX Solutions
to provide a comprehensive view of the trading activity by customers of INX Digital for the purpose of addressing Staff’s comment.

INX Digital

As noted in the prior response,
INX Digital represents the cryptocurrency trading platform with a performance obligation of providing a matching service for customers
buying and selling digital assets. INX Digital does not provide liquidity on its trading platform and does not represent a buyer to a
customer seller or a seller to a customer buyer in any trade. Under the guidance in IFRS 15.B34-38, INX Digital acts as an agent in satisfying
its performance obligation by arranging a match of a trade between a customer buyer and a seller and accordingly records revenue in the
amount of the trading fee.

We considered indicators
of control under the guidance in IFRS 15.B37 and based on the assessment, concluded that INX Digital does not have control of the assets.
INX Digital does not control the cryptocurrency being provided by the seller before it is transferred to the buyer. There is no transfer
of the actual asset when a trade occurs as all customer assets are held in an omnibus account (the trade is recorded on the internal
ledger in each customer account reflecting the quantity sold or purchased). INX Digital does not have market risk with regards to the
digital asset of its customers, and is not responsible to hold inventory or to settle the trade on behalf of a customer. INX Digital
also does not set the price for the cryptocurrency as the price is the market price established
electronically via orders submitted by buyers and sellers independent of INX Digital at various desired prices on the platform. The market
is established by INX customers (willing buyers and sellers) submitting orders to buy or sell digital assets and, therefore, forming
a natural public market.

    4

Control of an asset under
IFRS 15.33

According to IFRS 15.33, goods
and services are assets, even if only momentarily, when they are received and used. Control of an asset refers to the ability to:

 ● direct the use of, and obtain substantially all
of the remaining benefits from, the asset; or

 ● to prevent other entities from directing the
use of, and obtaining the benefits from, an asset.

The benefits of an asset are the potential cash
flows (inflows or savings in outflows) that can be obtained directly or indirectly in many ways, such as by:

 (a) using the asset to produce goods or provide services (including
public services);

 (b) using the asset to enhance the value of other assets;

 (c) using the asset to settle liabilities or reduce expenses;

 (d) selling or exchanging the asset;

 (e) pledging the asset to secure a loan; and

 (f) holding the asset.

Customer assets are held in an omnibus custodial
fiat account and omnibus wallets specifically desigated to hold customer funds for each cryptocurrency. Under the Digital User Agreement
between a customer and INX Digital, INX Digital does not have the right to use customer assets. Customer assets may not be loaned to INX
Digital or the Company and INX Digital may not grant security interest in customer assets to a third party, nor use them in any other
way – see Section 3, Ownership – Segregation, of the INX Digital User Agreement. INX Digital does not obtain any benefits
or cash flows from the assets because it does not use the assets in any way such as: to provide services or to settle other liabililties.
INX Digital does not sell or echange the assets, does not pledge them to secure a loan and does not gain a benefit by holding the assets.
Customer assets are simply custodied on behalf of INX customers in their original form for customers’ exclusive benefit.

Moreover, under the Digital
User Agreement, title to digital assets shall at all times remain exclusively with the customer and shall not transfer to INX Digital.
INX Digital shall