Crypto and digital assets

The Registrant directs the Staff to the disclosure at the end of the first paragraph of the referenced risk factor, which is set forth below: Chainlink has exhibited a historical annualized volatility of 104.63% and maximum annual price decrease of 85.87% over the past five years. November 18, 2025 Page 3

The Registrant respectfully acknowledges the Staff’s comment and notes that, under normal circumstances, the Fund’s portfolio holdings are consistent with the Fund’s “Principal Investment Strategies” section of the Prospectus. The Registrant notes that the Fund’s portfolio holdings as of December 31, 2024 were a result of an unusual circumstance that the Fund does not believe will be repeated, which is that the Fund was required to distribute approximately 31% of its total net assets. The Fund utilizes a long-flat trend-following strategy in which its portfolio is rotated between 100% exposure to Bitcoin Futures Contracts and 100% exposure to U.S. Treasury Securities. Accordingly, the Fund will either be: (1) long Bitcoin Futures Contracts with approximately 100% exposure to Bitcoin Futures Contracts; or (2) flat Bitcoin Futures Contracts and long U.S. Treasury Securities with…

The Registrant respectfully notes that the Funds utilize a “long-flat” trend-following investing strategy pursuant to which the Funds’ exposure alternates between 100% exposure to crypto asset Futures Contracts and 100% exposure to U.S. Treasury Securities. A long-flat strategy takes a long position when a trend is detected, seeking to take advantage of an anticipated increase in an asset’s value. However, when a downward trend is detected, the strategy exits the position and remains in cash or cash equivalents. The Funds' strategy is based upon a quantitative, proprietary signal that compares the respective crypto assets' 10-day and 20-day exponential moving average price, with a focus upon the price movement of Ether. The exponential moving average applies a weighting factor to each price point to give more weight to recent data to respond to new price changes and trends. The…

We have revised the disclosure on page 5 to include the requested information. We note that the dollar amount involved in the transactions with the related party through the date hereof totals $12,377, which is less than the $120,000/1% of the average assets threshold threshold under Item 404(d) of Regulation S-K. Although this transaction is not disclosable as a related party transaction, with the inability to speak with the Staff, Beeline elected to include the requested information. Risk Factors The sale or issuance of our common stock to C/M will create dilution, page 7

Pursuant to the Staff’s comment, the Registration Statement has been updated to reflect the revisions referenced in the prior comment.

The Company has amended disclosure on page 18 in response to the Staff’s comments. Risk Factors Risks Related to Our Business and Industry A particular crypto asset’s status as a “security” in any relevant jurisdiction is subject to a certain degree of uncertainty...., page 18

The Company has amended disclosure on page 18 in response to the Staff’s comments Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188. Very truly yours, /s/ Lawrence S. Venick Lawrence Venick Partner

We note the Staff’s comments, and in response hereto, respectfully advise the staff that we have not traded any Bitcoins on the OKX exchange and we noted that the OKX exchange is not available in the United States. We have revised on page 5 of the Registration Statement Amendment No. 5 that if we determine that it is necessary to sell Bitcoins to improve the cashflow, our CFO will instruct the Vice President to transfer the Bitcoins to the Coinbase exchange and execute the trade. We do not have an agreement with the Coinbase exchange. If the Bitcoins cannot be sold at the approved price within one day after the transfer, the CFO will review the recalibrated proposal prepared by the finance department and approve the new price and new number of Bitcoins to be sold if the CFO deems the proposal is reasonable. If we trade Bitcoins for fiat currency, we will withdraw the fiat currency…

• We are confirming that CBIT tokens may not be transferred to an external party. The CBIT instance of the Tassatpay platform is a closed loop environment, whereby a customer can only send a CBIT token to another customer of Customers Bank on the CBIT instant payments platform with an active CBIT wallet. The platform environment only permits the transfer of CBIT tokens to other customers that are on CBIT platform – customers that have a DDA with Customers Bank and that have been manually onboarded to CBIT platform, and that have an active CBIT wallet address. If a customer tries to send funds to a wallet outside the CBIT environment, the transaction will fail. • We are confirming that the CBIT tokens have no value or possible use outside of our CBIT payment platform. CBIT tokens cannot be transferred outside the CBIT payment platform. • There are no other ways to mint or burn CBIT…

We note the Staff’s comments, and in response hereto, respectfully advise the staff that we added the disclosure on page 5 of the Registration Statement Amendment No. 4 that our finance department is constantly monitoring the trend of Bitcoin price and will make proposals to our CFO. The CFO will determine whether the Bitcoin trading price is favorable and whether it is necessary for the Company to Bitcoins to improve the cashflow. If the CFO approves the trading of Bitcoins, she will instruct the Vice President to transfer the Bitcoins to the OKX exchange and execute the trade. We do not have an agreement with the OKX exchange. If the Bitcoins cannot be sold at the approved price within one day after the transfer, the CFO will review the recalibrated proposal prepared by the finance department and approve the new price and new number of Bitcoins to be sold if the CFO deems the proposal…

We note the Staff’s comments, and in response hereto, respectfully advise the staff that we do not have any business relationships and have no direct and material exposure to Voyager Digital, Genesis, BlockFi and Silvergate Capital. In addition, we have not experienced any service disruptions with or have our accounts closed by any banks or other financial institutions. We revised the disclosure under the section “Impact of Recent developments Regarding Crypto Asset Market” on page 11, the first risk factor on page 17, and the fourth risk factor on page 22 of the Registration Statement Amendment No. 4. Mining Facilities Cheyenne, Wyoming, page 9

● The Reward Coupons are coupons that happen to be digital in format. The digital coupons are not securities and are issued as ERC721 tokens, which are a standard for representing ownership of non-fungible tokens (NFTs), that is, where each token has a unique identifier. The NFTs are merely coupons for a future discount on services. The law regarding whether a particular digital asset, including NFTs, is a security is based on what is commonly referred to as the Howey Test which was enumerated in the seminal case, SEC v. W.J. Howey Col, 328 U.S. 293 (1946). The Howey Test looks at four factors: 1. An investment of money 2. In a common enterprise 3. With the expectation of profit 4. To be derived from the efforts of others Based thereon, the Reward Coupons are not securities as follows: ● Investment of money – the Reward Coupons are being issued for free to shareholders. ● Common…

It is simply too early to answer some of the questions you are asking about the cold wallet, security, or any segment that will first require our fully funding the build-out with the next stage development team in place and then planning the structuring of the writing of the code. That’s where we will see the newest and latest security technology, the best options for cold wallet storage and the most user friendly UX as it’s becoming more integrated with everyday users. It is our intention to build a highly secure, easy to use, non-custodial wallet. We plan to bring in the most advanced technology for security when we begin writing the code. We will have a cold wallet system that allows the users to transfer between storage and active modes and plan to include2FA, fingerprint and/or facial recognition technology. We plan to have multiple additional security daemons that review account…

The Company has amended the disclosure on page 9 in response to the Staff’s comments.

The Company has amended the disclosure on page 18 in response to the Staff’s comments. Los Angeles New York Chicago Nashville Washington, DC San Francisco Beijing Hong Kong www.loeb.com For the United States offices, a limited liability partnership including professional corporations. For Hong Kong office, a limited liability partnership. Ms. Jessica Livingston Securities and Exchange Commission Page 2

The Company has amended the disclosure on page 9 in response to the Staff’s comments.

The Company has amended the disclosure on page 9 in response to the Staff’s comments.

The Company has amended the disclosure on page 13 in response to the Staff’s comments.

The Company has not pledged any crypto assets to any parties since the start of crypto business and has amended the disclosure on page 9 in response to the comments.

The Company is unaware that the MetaWords NFTs currently held by its users serve as collateral for any other person or entity and has amended the disclosure on page 9 in response to the comments. Ms. Jessica Livingston Securities and Exchange Commission Page 3 Risk Factors, page 12

The Company has amended disclosure on pages 16 and17 in response to the Staff’s comments.

The Company has amended disclosure on page 17 in response to the Staff’s comments. Ms. Jessica Livingston Securities and Exchange Commission Page 4

The Company has amended disclosure on page 17 in response to the Staff’s comments.

The Company has amended disclosure on page 19 in response to the Staff’s comments.

The Company has amended disclosure on page 19 in response to the Staff’s comments.

The Company has amended disclosure on page 16 in response to the Staff’s comments. Should you have any questions relating to the foregoing or wish to discuss any aspect of the Company’s filing, please contact me at +852.5600.0188. Very truly yours, /s/ Lawrence S. Venick Lawrence Venick Partner

We note the Staff’s comments, and in response hereto, respectfully advise the staff that the Chief Executive Officer and Chief Financial Officer of the Company maintain countl of and have access to the private key. We have policy to safeguard our crypto assets. All the transactions involving the Bitcoins, such as withdrawing, transferring, or selling the Bitcoins from our wallet must be set up by the Vice President, authorized by the Chief Financial Officer and executed by the Chief Executive Officer. We also verbally confirm the wallet address with the receiver and perform a trial transaction with 0.01 Bitcoin before any transactions to verify the wallet address of the receiver. Additionally, we capture and keep record of the screenshots of the transactions and balance of the wallet on a daily basis. We revised the disclosure on page 6 of the Registration Statement Amendment No. 3.…

We note the Staff’s comments, and in response hereto, respectfully advise the staff that we revised the disclosure on page 6 of the Registration Statement Amendment No. 3 that from May 1, 2022 to November 30, 2022 the B itcoin price range was between $15,787 and $39,698; from December 1, 2022 to February 27, 2023, the B itcoin price range was between $16,440 and $24,829. In addition, we corrected “weighted average” to “average” of the hosting price. The breakeven price primarily illustrates the threshold that might result in negative cashflow for mining operation. We believe depreciation expenses is irrelevant to the threshold and shall not be a meaningful operation ratio for the management. We also revised the disclosure on page 5 of the Registration Statement Amendment No. 3 that if the Bitcoins price decreases when we trade the Bitcoins for fiat currency, the amount of fiat currency…

We note the Staff’s comments, and in response hereto, respectfully advise the staff that we revised the disclosure on page 13 and added a risk factor “Pending regulation related to electricity consumption by mining companies may impact our result of operation” on page [23] of the Registration Statement Amendment No. 3. Recent Developments, page 13

We note the Staff’s comments, and in response hereto, respectfully advise the staff that we revised the disclosure on page 22 of the Registration Statement Amendment No. 3 that we have pledged all of our Bitcoins as collateral for financing. We hope this response has addressed all of the Staff’s concerns relating to the comment letter. Should you have additional questions regarding the information contained herein, please contact our outside securities counsel William S. Rosenstadt, Esq. or Mengyi “Jason” Ye, Esq. of Ortoli Rosenstadt LLP at wsr@orllp.legal or jye@orllp.legal. Very truly yours, /s/ Lucas Wang Name: Lucas Wang Title: Chief Executive Officer

[Upstream] All shares of Nutriband common stock have been registered with the Commission and make up the entire number of shares issued and outstanding and have the same CUSIP/ISIN number. There are no differences in shareholder rights such as transferability. Shareholders may elect to hold their shares in depositories: Book Entry with TA, CEDE & Co or MERJ Dep. Digital securities on Upstream are interchangeable on terms that have the same meaning. The digital securities (or tokenized equities) are a digital representation of the company’s common stock that have been issued and registered with the Commission. A digital security is a 1:1 representation of a company’s common stock that acts as a receipt for the deposit or purchase and ownership of shares in the company. The digital recording of ownership is handled in the same manner as a database of shares issued to shareholders and, on…

We confirm that we are the counterparty to one custody arrangement. The custodied assets are stored and held in an account, in the Company’s name, for our benefit and the custodian has no right, interest, or title in those custodied assets. The custodied assets are at all times identifiable on the blockchain and in custodian’s database as being stored in the account for the benefit of the Company. In future filings we will make clear that the custodian has custody of our “Bitcoin” digital assets (or “Currencies” or “Currency”) of which the nature of the Bitcoin assets are described within Item 1 of our 10-K’s. We account for these currencies in accordance with ASC 350 as indefinite lived intangible assets which are initially recorded at fair value. Pursuant to guidance from ASC 820, the Company determines the nonrecurring fair value measurement using the quoted price of the Currency to…

As no explicit guidance is given within ASC 230 for the conversion of digital currencies and as there had been some divergence in industry practices, we presented the conversion of Bitcoin to fiat currency in the September 30, 2022 Form 10-Q with cash flows from investing activities. Upon further consideration, we believe that this activity would be better reflected within cash provided by operating activities as cash flows from the sale of Bitcoin are used to fund our business operations. Additionally, we do not currently hold any digital assets as investments. In the future we will include cash flows from the conversion of Bitcoin to fiat currency within cash provided by operating activities in our statements of cash flows.

We will revise our accounting to comply with ASC 350-30-35-19 and conform our disclosure related to digital currency fair value impairment testing. We will remove the reference to a “nightly” measurement when determining fair value for impairment testing and instead reference Bitcoin intraday lows as the measurement used for fair value testing. 8. Digital Currencies, page F-30 Comment No.

We will include a rollforward of our crypto asset holdings, showing additions, disposals (by sale or otherwise), gains and losses, along with disclosure about the nature of the additions (e.g. purchases, mining or staking rewards) and/or disposals within all future filings. Form 10-Q for the Quarterly Period Ended September 30, 2022 7. Property and Equipment, Net, page F-17 Comment No.

Prior to filing, we inspected the Bitcoin miners that are installed at the hosting facility in Texas and observed the following: · We were not restricted from accessing our mining equipment at the hosting facility in Texas; · The Bitcoin miners were inspected and appeared to be in good condition; · At the reporting date we were in discussions with operator of the facility to energize the equipment to allow us to begin mining operations; and · At the time of the filing management fully intended and expected the miners to begin mining within two to four weeks. Based on the above, we expected the mining equipment to be operational within a reasonable timeframe, which did not trigger an interim impairment assessment. * * * Should you have any questions regarding the foregoing, please do not hesitate to contact the undersigned at (949) 444-5464 or our General Counsel, Henry Nisser at (646)…

The Company has no current plans to offer digital dividends to shareholders. Upon consideration of issuing such dividends or coupons/rewards, all shareholders will be eligible to receive them. Notifications and access information will be provided via press releases and Form 8K, and any subsequent registration for dividends will also be communicated upon its effectiveness.

The Company acknowledges the Staff’s comment and respectfully submits that the impact of crypto asset market developments on the Company continues to be indirect, and such impacts were described in the following sections of the 10-K: • Part I Item 1. Business – Government Regulation • Part I Item 1A Risk Factors – Risks Related to Our Business – The digital asset exchange on which cryptocurrencies, including bitcoin, trade are relatively new and largely unregulated, and thus may be exposed to fraud and failure. Such failures may result in a reduction in the price of bitcoin and other cryptocurrencies and can adversely affect an investment in us. DOCPROPERTY "CUS_DocIDChunk0" 156137991v3 • Part I Item 1A Risk Factor – Risks Related to Our Securities – The price of our common stock may be volatile and could fluctuate widely, which could result in substantial losses for investors. The…

The Company acknowledges the Staff’s comment and respectfully submits that it included an analysis of the profitability of its bitcoin mining operations under the heading “Bitcoin Mining Operations” in the Management’s Discussion and Analysis of Financial Condition and Results of Operations section of the Quarterly Report. The Company further confirms that it will update such disclosure as appropriate in future filings. Lines of Business, page 5

The Company acknowledges the Staff’s comment and confirms, as disclosed under the heading “Lines of Business” in the Management’s Discussion and Analysis of Financial Condition and Results of Operations section of the Quarterly Report, that it has no intention to mine or produce any other cryptocurrencies at this time. If such intent changes, it will include such disclosure in future filings. The Company further confirms that it will disclose the information requested regarding material strategic acquisitions in its 2023 10-K and in other applicable future filings.

The Company acknowledges the Staff’s comment and will disclose the information requested in its 2023 10-K and in other applicable future filings. In addition to bitcoin, the Company does hold de minimis amounts of the following digital assets: • 1.36 Sustainable Bitcoin Certificates (SBC) issued by the Sustainable Bitcoin Protocol, a startup organization that aims to encourage miners to utilize environmentally friendly energy sources. The Company was awarded 21.36 SBCs, 20.0 of which were exchanged for $10,000 value of USD Coin (USDC), a crypto asset, which the Company currently holds as disclosed under the heading “Lines of Business” in the Management’s Discussion and Analysis of Financial Condition and Results of Operations section of the Quarterly Report as of December 31, 2022. The Company does not believe the 1.36 SBCs have an accounting value as there is no current liquid market…

The Company acknowledges the Staff’s comment and will disclose the information requested in its 2023 10-K and in other applicable future filings. Cybersecurity, Page 10

The Company acknowledges the Staff’s comment and will disclose the information requested in its 2023 10-K and in other applicable future filings.

The Company acknowledges the Staff’s comment and respectfully submits that the 10-K includes a risk factor “The properties included in our mining operation may experience damages, including damages that may not be covered by insurance,” which discloses insurance risk with respect to our miners. The Company further submits that the Quarterly Report includes a new risk factor “Our lack of insurance protection exposes us and our shareholders to the risk of loss of our bitcoin for which DOCPROPERTY "CUS_DocIDChunk0" 156137991v3 no person is liable,” which discloses insurance risk with respect to our bitcoin. The Company further submits that the above named risk factors include all material information regarding insurance risk. The value of bitcoin has historically been subject to wide swings, page 17

The Company acknowledges the Staff’s comment and respectfully submits that the risk factor has been updated in the Quarterly Report to include quantitative information regarding the wide swings of bitcoin prices. If the SEC or another regulatory body consider bitcoin to be a security, page 28

The Company acknowledges the Staff’s comment and confirms that, as disclosed under the heading “Lines of Business” in the Management’s Discussion and Analysis of Financial Condition and Results of Operations section of the Quarterly Report, it has no intention to mine or produce any other cryptocurrencies at this time. If such intent changes, it will include the disclosure requested above in future filings. Management’s Discussion and Analysis of Financial Condition and Results of Operations Results of Operations for the Year Ended September 30, 2022 and 2021, page 37

The Company acknowledges the Staff’s comment and submits that, taking into account guidance provided in Questions 100.01 and 102.03 of the Compliance and Disclosure Interpretations (as updated on December 13, 2022), it clarified in its non-GAAP measures disclosure in the Quarterly Report to state that some of the excluded items involve cash outlays and some of them recur on a regular basis but that management does not believe any such items are normal operating expenses necessary to generate bitcoin related revenues. The Company also notes that it removed any disclosure implying that all such adjustments were non-recurring. The Company further submits that the new disclosure specifically identifies each adjustment to Adjusted EBITDA, including each non-cash line item, and each such item is quantified in the reconciliation table. The Company further notes that similarly modified the…

The Company acknowledges the Staff’s comment and respectfully submits that the Company has analyzed the revenue requirements under ASC 606 as follows: Step 1 of ASC 606 The Company noted the following requirements pursuant to ASC 606-10-25-1: “An entity shall account for a contract with a customer that is within the scope of this Topic only when all of the following criteria are met: a) The parties to the contract have approved the contract (in writing, orally, or in accordance with other customary business practices) and are committed to perform their respective obligations. b) The entity can identify each party’s rights regarding the goods or services to be transferred. c) The entity can identify the payment terms for the goods or services to be transferred. d) The contract has commercial substance (that is, the risk, timing, or amount of the entity’s future cash flows is expected to…

The Company acknowledges the Staff’s comment and respectfully submits that the Company’s transaction fee revenue does not require any amounts other than bitcoin, and therefore, there is no additional considerations under ASC 606-10-50-4 for disclosure. Bitcoin rewards are typically deposited the next day after earning such rewards and such bitcoin received are rounded to four decimal places (ten-thousandths).

The Company acknowledges the Staff’s comment and respectfully submits that the Company has removed any such statements from the Quarterly Report. Concentration of Credit Risk, page F-13

The Company acknowledges the Staff’s comment and respectfully submits that the Company made the necessary change in the Quarterly Report. 2022 Goodwill Impairment Analysis, page F-16 DOCPROPERTY "CUS_DocIDChunk0" 156137991v3

The Company acknowledges the Staff’s comment and respectfully submits that the Company values each bitcoin (or fraction thereof) individually at the fair value on the date it was mined. Each of these individual bitcoins which are held at the quarter end are then evaluated for impairment based on their respective carrying basis. The impairment analysis on bitcoin, performed quarterly, compares the carrying amount of each bitcoin to the lowest daily closing bitcoin price during such quarter. The fair value of bitcoin pricing is derived daily from NASDAQ.com and the Company compares the quoted price from NASDAQ.com to other sources to ensure there is no material variance in quoted pricing. The Company selected NASDAQ.com due to its consistent daily activity, whereas other sources were not as reliable on a daily basis. The Company utilizes quotes from NASDAQ.com to impair its bitcoin…

The Company acknowledges the Staff’s comment and respectfully submits that the Company believes the Staff was referring to ASC 210-10-20 and the Company’s response will reflect its analysis of that codification section. ASC 210-10-20 notes that current assets are defined as follows: “Current assets is used to designate cash and other assets or resources commonly identified as those that are reasonably expected to be realized in cash or sold or consumed during the normal operating cycle of the business.” The Company converts bitcoin to USD to cover its various operating and capital expenditures on a frequent basis. Since bitcoins are delivered to the Company’s wallet within a day of earning the bitcoin, the Company has immediate access to convert the bitcoin to USD or send bitcoin to vendors as payment. The Company held 595 bitcoin as of September 30, 2022, which approximately…

In response to the Staff’s comment, the Company respectfully notes that it provides the following services for all crypto assets available on its platform: ● Crypto assets trading (such as BTC, ETH, AVAX); ● Security tokens listing and trading; and ● Capital raise services through primary offerings. INX.ONE is a platform for trading and investing in digital assets, i.e. crypto assets and security tokens. There are two entities behind each type of asset classes – (i) INX Digital, Inc. (“INXD”), which is utilized for crypto assets dealing and has a license to operate in 43 states in the United States (“U.S.”) plus Washington D.C and Puerto Rico (for state licenses please see: https://www.inx.co/legal/state-licenses/); and (ii) INX Securities, LLC (“INX Securities”, or “INXS”), a FINRA-registered broker-dealer and operator of an alternative trading system (“ATS”), which has duly filed its…

In response to the Staff’s comment, the Company intends to describe risks and limitations of its internal policies and procedures for determining whether or not a crypto asset is a security by including the following risk factor in the Company’s upcoming annual report on Form 20-F: A particular crypto asset’s status as a “security” in any relevant jurisdiction is subject to a high degree of uncertainty. If the Company is unable to properly characterize a digital asset listed for trading as a “security”, it may be subject to regulatory scrutiny, inquiries, investigations, fines, and other penalties, which may adversely affect the business, operating results, and its financial condition. The Commission and its staff have taken the position that certain crypto assets fall within the definition of a “security” under the U.S. federal securities laws. The legal test for determining whether…

In response to the Staff’s comment, the Company intends to include the following risk factors in the Company’s upcoming annual report on Form 20-F: We are subject to an extensive and highly-evolving regulatory landscape and any adverse changes to, or our failure to comply with, any laws and regulations could adversely affect our brand, reputation, business, operating results, and financial condition. INX Securities is registered with FINRA and the SEC as a broker-dealer authorized to operate as an ATS that is allowed to facilitate the trading of security tokens in compliance with the SEC’s “Three-Step Process.” Additionally, INX Securities is registered in all 50 U.S. states, the District of Columbia, and Puerto Rico, and is also permitted to act as the broker-dealer of record in primary offerings for traditional and digital securities. As such, the Company has implemented policies,…

In response to the Staff’s comment, the Company intends to include the following disclosure in the Company’s upcoming annual report on Form 20-F: Adding crypto assets to, or removing from our platform As to the Company’s general process for adding an asset to the platform and our evaluation thereof, please see our response to comment 3 above. As specified in our response to comment 3, the Company has a policy and process in place for adding new crypto asset securities and cryptocurrencies for listing or trading on its platform. The Company’s legal and compliance teams, in cooperation with the Chief Compliance Officer, the legal, compliance, technology, cybersecurity, and operational risks with respect to listing a cryptocurrency. The evaluation is done in the form of a due diligence checklist, upon which the above parties have to signify approval, and once this is done, the checklist is…

In response to the Staff’s comment, the Company respectfully notes that none of its or its client’s crypto assets are currently held in cold wallets. ● whether any persons (e.g., auditors, etc.) are responsible for verifying the existence for the crypto assets held by the third-party custodian(s); Greenberg Traurig, LLP | Attorneys at Law www.gtlaw.com U.S. Securities and Exchange Commission February 21, 2023 Page 21

In response to the Staff’s comment, the Company intends to disclose the crypto assets it accepts as payment fees, how it determines the value of such crypto assets and its policies related to monetizing such crypto assets by including the following language in the Company’s upcoming annual report on Form 20-F: Crypto assets as payment fees for crypto and security token services With regards to trading of digital assets, a transaction fee is charged and deducted from the customer account at the time of the order execution. The transaction fee is set as a percentage of the transaction value based on the fee schedule published on the Company’s website (https://www.inx.co/fee-schedules/) and is charged in the currency of the consideration paid by the customer. For example, if a customer buys BTC with USD, the transaction fee would be charged in USD. The same process is followed with regards…

In response to the Staff’s comment, the Company respectfully notes that it is exploring options such as obtaining a Designated Contract Markets (“DCM”) license with the CFTC, but has not made an affirmative decision to pursue this application at this time. Should this path change, the Company will advise the Staff and provide adequate disclosure in its future filings. Greenberg Traurig, LLP | Attorneys at Law www.gtlaw.com U.S. Securities and Exchange Commission February 21, 2023 Page 24