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December 15, 2023

Terig Hughes
Chief Financial Officer
VolitionRx Limited
1489 West Warm Springs Road, Suite 110
Henderson, NV 89014

Re: VolitionRx Limited
Form 10-K for
Fiscal Year Ended December 31, 2022
File No. 001-36833

Dear Terig Hughes:

We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment.

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.

Form 10-K for Fiscal Year Ended December 31, 2022

Item 9A. Controls and Procedures
Management's Report on Internal Control Over Financial Reporting, page
76

1. We note that you
identified material weaknesses in your internal control over financial
reporting as of
December 31, 2022. Please revise future filings to clearly describe each
specific material
weakness identified and definitively state managements conclusion of
the effectiveness of
your internal control over financial reporting. Refer to Item 308(a)(3)
of Regulation S-K.
In closing, 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.
Terig Hughes
VolitionRx Limited
December 15, 2023
Page 2

Please contact Tara Harkins at 202-551-3639 or Kevin Kuhar at
202-551-3662 with any
questions.



FirstName LastNameTerig Hughes Sincerely,
Comapany NameVolitionRx Limited
Division of Corporation
Finance
December 15, 2023 Page 2 Office of Life Sciences
FirstName LastName