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April 29, 2024
Mark Blick
Chief Executive Officer and Director
Diginex Ltd
Smart-Space Fintech 2, Room 3
Unit 401-404 Core C
Cyberport, Telegraph Bay
Hong Kong
Re:Diginex Ltd
Amendment No. 1 to Draft Registration Statement on Form F-1
Submitted April 2, 2024
CIK No. 0002010499
Dear Mark Blick:
            We have reviewed your amended draft registration statement and have the following
comments.
            Please respond to this letter by providing the requested information and either submitting
an amended draft registration statement or publicly filing your registration statement on
EDGAR. If you do not believe a comment applies to your facts and circumstances or do not
believe an amendment is appropriate, please tell us why in your response.
            After reviewing the information you provide in response to this letter and your amended
draft registration statement or filed registration statement, we may have additional
comments. Unless we note otherwise, any references to prior comments are to comments in our
March 11, 2024 letter.
Amended Draft Registration Statement of Form F-1 Submitted April 2, 2024
Summary, page 1
1.We note your response to prior comment three regarding the office arrangements for your
principal executive offices in Hong Kong. Please clarify here and on page 70 whether
your Hong Kong principal executive offices is a co-working shared space facility and
clarify if most of your employees and operations occur at this facility or are performed
virtually.

 FirstName LastNameMark Blick
 Comapany NameDiginex Ltd
 April 29, 2024 Page 2
 FirstName LastName
Mark Blick
Diginex Ltd
April 29, 2024
Page 2
Business
Our Business Lines, page 67
2.Please provide your revenues by geographic area for each of the following countries
originating from the United States of America, United Kingdom, Hong Kong and
Singapore. We note your disclosure combines the revenue sourced to these four countries
as approximately 80% of your total revenues for the March year ended March 31, 2023.
Please provide further specificity by country.
3.We note your response to prior comment 21 regarding your channel partners. Please
clarify whether you derive a material amount of your revenues from your reselling or
distribution agreements with either HSBC or Fitch Ratings.
Principal Securityholders, page 98
4.We reissue prior comment 32 in part, please disclose the natural person(s) that ultimately
has the investment and/or voting power over the shares beneficially owned by HBM IV,
Inc.
Financial Statements
3 Significant Accounting Policies
Research and development expenditure, page F-36
5.Disclose research and development expense as required by paragraphs 126 and 127 of IAS
38 and paragraphs 104 and 105 of IAS 1.
            Please contact Joseph Kempf at 202-551-3352 or Robert Littlepage at 202-551-3361 if
you have questions regarding comments on the financial statements and related matters. Please
contact Edwin Kim at 202-551-3297 or Matthew Crispino at 202-551-3456 with any other
questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       James A. Prestiano, Esq.