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March 1, 2024
Anastasios Arima
Chief Executive Officer
IperionX Ltd
129 W Trade Street
Suite 1405
Charlotte, NC 28202
Re:IperionX Ltd
Form 20-F/A for the Fiscal Year ended June 30, 2023
Filed February 20, 2024
Response Dated February 20, 2024
File No. 001-41338
Dear Anastasios Arima:
            We have reviewed your February 20, 2024 amendment and response to our comment
letter and have the following comments.
            Please respond to this letter 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 a
comment applies to your facts and circumstances, please tell us why in your response.
            After reviewing your response to this letter, we may have additional comments. Unless
we note otherwise, any references to prior comments are to comments in our February 7,
2024 letter.
Form 20-F for the Fiscal Year ended June 30, 2023
General
1.We note from your response to prior comment 1 that you would prefer to limit furnishing
quarterly financial information and certain other information previously filed in Australia
to quarterly financial information for the quarters ended September 30, 2023 and
December 31, 2023, and that you agree to timely furnish on future Form 6-Ks future
quarterly financial and other information you file in Australia.

However, we continue to believe that you should furnish all material information,
including quarterly financial information, that you previously filed in Australia beginning
from the effective date of your registration statement, i.e. on or after June 15, 2022.

 FirstName LastNameAnastasios Arima
 Comapany NameIperionX Ltd
 March 1, 2024 Page 2
 FirstName LastName
Anastasios Arima
IperionX Ltd
March 1, 2024
Page 2
Information on the Company, page 52
2.We note your response to prior comment 2, indicating disclosure was made in the
amendment to provide clarification with respect to your cut-off grade.  However, it
remains unclear how the cut-off grade details provided in your amendment and response
support the 0.4% THM cut-off grade and it appears that your revenue cost break even
calculation may be using a 2.2 THM%, which is the average grade of the mineral
resource, rather than the 0.4% cut-off grade.  For example, based on the information in
Annex A, including the THM%, the THM assemblage %, the recovery factors, the mineral
pricing, and the royalty rate, it does not appear that the revenue generated from a 0.4%
THM block of material would cover the production cost.

As defined in Item 1300 of Regulation S-K, the cut-off grade is the grade that
determines the destination of the material during mining, i.e. for the purposes of
establishing the prospects of economic extraction, it is the grade that distinguishes
material deemed to have no economic value from material deemed to have economic
value. Tell us how the 0.4% THM cut-off grade you have disclosed is consistent with this
definition in your view, and provide us with the calculations you believe demonstrate
consistency with the details in the amendment and Annex A of your response.
            Please contact John Coleman at 202-551-3610, or Karl Hiller at 202-551-3686 with
questions regarding comments on your mineral properties, or Sondra Snyder at 202-551- 3332 or
Gus Rodriguez at 202-551-3752, if you have questions on the other matters.
Sincerely,
Division of Corporation Finance
Office of Energy & Transportation