SecProbe.io

March 12, 2020
Robert Kerris
Chief Financial Officer
Ebix, Inc.
1 Ebix Way
Johns Creek, Georgia 30097
Re:Ebix, Inc.
Form 10-K for the fiscal year ended December 31, 2019
Form 8-K filed March 2, 2020
File No. 000-15946
Dear Mr. Kerris:
            We have reviewed your filing and have the following comments.  In some of our
comments, we may ask you to provide us with information so we may better understand your
disclosure.
            Please respond to these comments 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 our
comments apply to your facts and circumstances, please tell us why in your response.
            After reviewing your response to these comments, we may have additional comments.
Form 10-K for the fiscal year ended December 31, 2019
Item 7. Management's Discussion and Analysis of Financial Condition and Results of Operations
Overview, page 32
1.Tell us why you do not include a discussion of how the Yatra combination is expected to
impact your financial condition and operating performance.  In this regard, the pending
acquisition including its purchase price consideration and allocation will have a significant
impact on your trends.  We further note that Series Y Convertible preferred stock ("Series
Y") will be issued as consideration for this acquisition and this stock is listed on your
balance sheet.  Please provide your analysis of the redemption feature and support how
you intend to classify the Series Y shares in your balance sheet.  Tell us how you will
account and value the redemption feature or put right embedded in the preferred shares.
Further, tell us how you will determine the fair value the Series Y shares.  Cite the
authoritative literature you relied upon to support your accounting.  We refer you
to Section III.A of SEC Release No. 33-8350.

 FirstName LastNameRobert Kerris
 Comapany NameEbix, Inc.
 March 12, 2020 Page 2
 FirstName LastNameRobert Kerris
Ebix, Inc.
March 12, 2020
Page 2
Valuation of Goodwill, page 47
2.You disclose that you have considered the guidance within ASC 350 and ASC 280 in
concluding that you effectively operate as one reporting unit which appears to be a change
from four reporting units.  Please tell us if you performed an interim goodwill impairment
test of your four goodwill reporting units in the third quarter as a result of the change.  For
any interim impairment test performed, tell us the results of the test and the percentage by
which the fair value exceeded the carrying value.  If no interim impairment test was
performed, please tell us how you concluded that there were no triggering events
necessitating an impairment test in light of the change in the composition and carrying
amounts of your reporting units.  We refer you to ASC 350-20-35-30 and 350-20-35-3C.
Notes to Consolidated Financial Statements
Revenue Recognition and Contract Liabilities, page 69
3.Your response to prior comment 2 includes two statements (1) “the license does not exist
in accordance with paragraph 606-10-55-54(a)” and (2) “We do have separate software
licensing arrangements that provide the customer the right to use software.”  Please clarify
how these two statements apply to your SaaS arrangements.  Revise your disclosure to
clearly identify the performance obligations included in Insurance Exchange arrangements
(i.e. SaaS, licensing, etc.) and whether those arrangements include or do not include the
license of intellectual property under ASC 606.  Indicate whether some arrangements
contain a software license which is recognized at a point in time.  Describe how fees for
hosting the SaaS performance obligation are charged and indicate whether the transaction
fees are payments for those services.  Clarify the nature of Subscription services as the
disclosure indicates that this service primarily consist of post-contract support services.  In
addition, please provide disclosures of revenues recognized at a point in time and over
time for each product line disclosed in your footnote.  We refer you to ASC 606-10-50-
91(f).
4.You disclose that variable consideration and transaction fees under your SaaS
arrangements are recognized by applying the invoice expedient in ASC 606-10-55-18.
Explain whether the performance obligations under these arrangements are a series of
distinct goods or services pursuant to paragraph ASC 606-10-25-14(b).  If so, explain why
you do not recognize the variable consideration in accordance with ASC 606-10-32-39
through 40 instead of utilizing the invoice expedient.
Form 8-K filed March 2, 2020
Reconciliation of EBITDA, GAAP net income and diluted earnings per share to non-GAAP net
income and diluted earnings per share, page 3
5.Please tell us how you determined the Non-GAAP Adjustments to calculate the Non-
GAAP Net Income and Non-GAAP Operating Income were one-time and non-recurring
in nature as these items appear to be a part of operational and normal expenditures.  Refer

 FirstName LastNameRobert Kerris
 Comapany NameEbix, Inc.
 March 12, 2020 Page 3
 FirstName LastName
Robert Kerris
Ebix, Inc.
March 12, 2020
Page 3
to Question 100.01, 100.04, and 102.03 of the Non-GAAP Compliance and Disclosure
Interpretations as well as  Item 10(e)(1)(ii)(B) of Regulation S-K.

            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.
            You may contact Amanda Kim, Staff Accountant, at (202) 551-3241 or Stephen
Krikorian, Accounting Branch Chief, at (202) 551-3488 if you have questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       Robin Raina, Chief Executive Officer