Mail Stop 4561 May 11, 2018 Alex Mardikian Chief Executive Officer OBITX, Inc. 4720 Salisbury Road Jacksonville, FL 32256 Re: OBITX, Inc. Amendment No. 2 to Registration Statement on Form S-1 Filed May 7, 2018 File No. 333-222978 Dear Mr. Mardikian: Our preliminary review of your registration statement indicates that it fails in numerous material respects to comply with the requirements of the Securities Act of 1933, the rules and regulations under that Act, and the requirements of the form. Specifically, we are unable to complete a review of the registration statement as your financial statements do not meet the updating requirements of Rule 8-08 of Regulation S-X. In addition, the audit report does not conform to PCAOB Release No. 2017-001 and a current auditor consent must be filed. Therefore, we will not perform a detailed examination of the registration statement and we will not issue comments. We suggest that you consider filing a substantive amendment to correct the deficiencies. If you were to request acceleration of the effective date of the registration statement in its present form, we would likely recommend that the Commission deny your request. Sincerely, /s/ Jan Woo Jan Woo Legal Branch Chief Office of Information Technologies and Services cc: Thomas G. Amon Law Office of Thomas G. Amon