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October 19, 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
Response dated September 29, 2022
File No. 001-39600
Dear Jonathan Farnell:
            We have reviewed your September 29, 2022 response to our comment letter and have the
following comment.  In our comment, we may ask you to provide us with information so we may
better understand your disclosure.
            Please respond to this comment 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
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this comment, we may have additional
comments.  Unless we note otherwise, our references to prior comments are to comments in our
September 16, 2022 letter.
Form 20-F for the Fiscal Year Ended March 31, 2022
Item 3. Key Information, page 6
1.We note your response to comment 2, your proposed new risk factor to be included in
future Form 20-F filings and reissue.  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 limitations.  State whether or not you have established cash management policies

 FirstName LastNameJonathan Farnell
 Comapany NameEQONEX Limited
 October 19, 2022 Page 2
 FirstName LastName
Jonathan Farnell
EQONEX Limited
October 19, 2022
Page 2
relating to the transfer of funds through your organization and describe them, as
applicable.  Lastly, 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.  In this regard, we note
that the proposed new risk factor only addressed limited portions of comment 2 and was
presented as a standalone risk factor versus as an introduction to Item 3.  Please
supplementally provide us with your proposed revised disclosure which addresses the full
comment.
            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