EXHIBIT 31

             Form of Certification for Form 10-Q

                       CERTIFICATIONS

I, Joseph P. Martori, Chairman, and Chief Executive Officer
of ILX Resorts Incorporated (the "Company") certify that:

               1.   I have reviewed this quarterly report on
          Form 10-Q of ILX Resorts Incorporated;

     2.   Based on my knowledge, this quarterly report does
          not contain any untrue statement of a material
          fact or omit to state a material fact necessary to
          make the statements made, in light of the
          circumstances under which such statements were
          made, not misleading with respect to the period
          covered by this quarterly report;

     3.   Based on my knowledge, the financial statements,
          and other financial information included in this
          quarterly report, fairly present in all material
          respects the financial condition, results of
          operations and cash flows of the registrant as of,
          and for, the periods presented in this quarterly
          report;

     4.   The registrant's other certifying officers and I
          are responsible for establishing and maintaining
          disclosure controls and procedures (as defined in
          Exchange Act Rules 13a-14 and 15d-14) for the
          registrant and have:

          a)   designed such disclosure controls and procedures to
            ensure that material information relating to the registrant,
            including its consolidated subsidiaries, is made known to us
            by others within those entities, particularly during the
            period in which this quarterly report is being prepared;

          b)   evaluated the effectiveness of the registrant's
            disclosure controls and procedures as of a date within 90
            days prior to the filing date of this quarterly report (the
            "Evaluation Date"); and

          c)   presented in this quarterly report our conclusions
            about the effectiveness of the disclosure controls and
            procedures based on our evaluation as of the Evaluation
            Date;

         5.   The registrant's other certifying officers
          and I have disclosed, based on our most recent
          evaluation, to the registrant's auditors and the
          audit committee of registrant's board of directors
          (or persons performing the equivalent functions):

          a)   all significant deficiencies in the design or operation
            of internal controls which could adversely affect the
            registrant's ability to record, process, summarize and
            report financial data and have identified for the
            registrant's auditors any material weaknesses in internal
            controls; and

          b)   any fraud, whether or not material, that involves
            management or other employees who have a significant role in
            the registrant's internal controls; and

         6.   The registrant's other certifying officers
          and I have indicated in this quarterly report
          whether there were significant changes in internal
          controls or in other factors that could
          significantly affect internal controls subsequent
          to the date of our most recent evaluation,
          including any corrective actions with regard to
          significant deficiencies and material weaknesses.

Date:  November 11, 2003

                              /s/Joseph P. Martori
                              --------------------
                              Joseph P. Martori
                              Chairman and Chief Executive
                                  Officer





             Form of Certification for Form 10-Q

                       CERTIFICATIONS

I, Margaret M. Eardley, Executive Vice President and Chief
Financial Officer of ILX Resorts Incorporated (the
"Company") certify that:

               1.   I have reviewed this quarterly report on
          Form 10-Q of ILX Resorts Incorporated;

     2.   Based on my knowledge, this quarterly report does
          not contain any untrue statement of a material
          fact or omit to state a material fact necessary to
          make the statements made, in light of the
          circumstances under which such statements were
          made, not misleading with respect to the period
          covered by this quarterly report;

     3.   Based on my knowledge, the financial statements,
          and other financial information included in this
          quarterly report, fairly present in all material
          respects the financial condition, results of
          operations and cash flows of the registrant as of,
          and for, the periods presented in this quarterly
          report;

     4.   The registrant's other certifying officers and I
          are responsible for establishing and maintaining
          disclosure controls and procedures (as defined in
          Exchange Act Rules 13a-14 and 15d-14) for the
          registrant and have:

          a)   designed such disclosure controls and procedures to
            ensure that material information relating to the registrant,
            including its consolidated subsidiaries, is made known to us
            by others within those entities, particularly during the
            period in which this quarterly report is being prepared;

          b)   evaluated the effectiveness of the registrant's
            disclosure controls and procedures as of a date within 90
            days prior to the filing date of this quarterly report (the
            "Evaluation Date"); and

          c)   presented in this quarterly report our conclusions
            about the effectiveness of the disclosure controls and
            procedures based on our evaluation as of the Evaluation
            Date;

         5.   The registrant's other certifying officers
          and I have disclosed, based on our most recent
          evaluation, to the registrant's auditors and the
          audit committee of registrant's board of directors
          (or persons performing the equivalent functions):

          a)   all significant deficiencies in the design or operation
            of internal controls which could adversely affect the
            registrant's ability to record, process, summarize and
            report financial data and have identified for the
            registrant's auditors any material weaknesses in internal
            controls; and

          b)   any fraud, whether or not material, that involves
            management or other employees who have a significant role in
            the registrant's internal controls; and

         6.   The registrant's other certifying officers
          and I have indicated in this quarterly report
          whether there were significant changes in internal
          controls or in other factors that could
          significantly affect internal controls subsequent
          to the date of our most recent evaluation,
          including any corrective actions with regard to
          significant deficiencies and material weaknesses.

Date:  November 11, 2003

                              /s/Margaret M. Eardley
                              ----------------------
                              Margaret M. Eardley
                              Executive Vice President and
                                  Chief Financial Officer