United States securities and exchange commission logo February 2, 2021 Richard Byworth Chief Executive Officer Diginex Ltd 35/F Two International Finance Centre 8 Finance Street, Central Hong Kong Re: Diginex Ltd Registration Statement on Form F-1 Filed January 29, 2021 File No. 333-252530 Dear Mr. Byworth: This is to advise you that we have not reviewed and will not review your registration statement. Please refer to Rules 460 and 461 regarding requests for acceleration. 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. Please contact Taylor Beech at 202-551-4515 with any questions. Sincerely, Division of Corporation Finance Office of Trade & Services cc: David A. Sakowitz, Esq.