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September 16, 2022
Jonathan Farnell
Chief Executive Officer
EQONEX Limited
118 Piccadilly
Mayfair, London W1J 7NW
United Kingdom
Re:EQONEX Limited
Form 20-F for the Fiscal Year Ended March 31, 2022
Filed August 15, 2022
File No. 001-39600
Dear Mr. Farnell:
            We have reviewed your filing 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.
Form 20-F for the Fiscal Year Ended March 31, 2022
Item 3. Key Information, page 6
1.Please revise to discuss the Hong Kong laws and regulations that apply to you, any
permissions or approvals from Hong Kong authorities that you are required to obtain and
whether you have done so, and the related risks and consequences.  Supplementally
provide us with your proposed revised disclosure.
2.Please amend your disclosure to describe how cash is transferred through your
organization and disclose your intentions to distribute earnings or settle amounts owed.
State whether or not any transfers, dividends, or distributions have been made to date
between the holding company and its subsidiaries, or to investors, and quantify the
amounts where applicable.  Discuss whether there are limitations on your ability to
transfer cash between you, your subsidiaries or investors, as well as the source of any such

 FirstName LastNameJonathan Farnell
 Comapany NameEQONEX Limited
 September 16, 2022 Page 2
 FirstName LastName
Jonathan Farnell
EQONEX Limited
September 16, 2022
Page 2
limitations.  State whether or not you have established cash management policies relating
to the transfer of funds through your organization and describe them, as
applicable.  Please amend your disclosure to state that, to the extent cash or assets in the
business is in Hong Kong or a Hong Kong entity, the funds or assets may not be available
to fund operations or for other use outside of Hong Kong due to interventions in or the
imposition of restrictions and limitations on the ability of you or your subsidiaries by the
PRC government to transfer cash or assets.  Supplementally provide us with your
proposed revised disclosure.
Item 15. Controls and Procedures, page 97
3.You state this annual report does not include a report of management’s assessment
regarding internal control over financial reporting due to the transition period established
by rules of the SEC for newly public companies.  However, we note that you filed an
annual report on Form 20-F for the year ended March 31, 2021 pursuant to section 13(a)
or 15(d) of the Exchange Act.  Please tell us how you have considered Instruction 1 to
Item 15 of Form 20-F in determining that you were not required to provide management’s
report on internal control over financial reporting in your Form 20-F for the year ended
March 31, 2022.
            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.
            You may contact Tony Watson at (202) 551-3318 or Joel Parker at (202) 551-3651 if you
have questions regarding comments on the financial statements and related matters.  Please
contact Donald Field at (202) 551-3680 or Lilyanna Peyser at (202) 551-3222 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Trade & Services