SecProbe.io

January 27, 2020
Alfred Poor
Chief Executive Officer
Ideanomics, Inc.
55 Broadway, 19th Floor
New York, NY 10006
Re:Ideanomics, Inc.
Registration Statement on Form S-1/A
Filed on December 31, 2019
File No. 333-224382
Dear Mr. Poor:
            We have reviewed your amended registration statement 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 this letter by amending your registration statement and providing the
requested information.  If you do not believe our comments apply to your facts and
circumstances or do not believe an amendment is appropriate, please tell us why in your
response.
            After reviewing any amendment to your registration statement and the information you
provide in response to these comments, we may have additional comments.  Unless we note
otherwise, our references to prior comments are to comments in our August 9, 2019 letter.
Form S-1 filed December 31, 2019
The Offering, page 10
1.We note your disclosure that approximately 20 million additional shares will be
outstanding after the offering.  Please provide further detail as to how these additional
shares will become outstanding.
Overview, page 37
2.We note your response to comment 9, the memo accompanying your responses, the
revised disclosure on page 37 and elsewhere in your filing.  We understand that through
Asia EDX you distributed and traded GTB tokens in exchange for Bitcoin and Ether.  In
light of such distribution and trading, the GTB token holders' inability to convert such

 FirstName LastNameAlfred  Poor
 Comapany NameIdeanomics, Inc.
 January 27, 2020 Page 2
 FirstName LastNameAlfred  Poor
Ideanomics, Inc.
January 27, 2020
Page 2
tokens into fiat, and additionally, the apparent lack of functional applications on the GTD
blockchain, please provide us a detailed analysis and your conclusions with respect to the
following.
•Explain to us whether GTB tokens may be deemed a security.  In this regard, we note
your disclosure on page 21 that "speculators and investors who seek to profit from
trading and holding GTB currently account for a significant portion of GTB
demand."  On page F-47, you further state that "the value of GTB is determined by
the value that various market participants place on GTB through their transactions.
GTB holders make or lose money from buying and selling GTB."  We also note
GTB's trading history which you provided supplementally and your reference to the
four-part Howey test on page 78.
•Tell us whether your distribution of GTB tokens through the Asia EDX in exchange
for Bitcoin and Ether may be deemed an initial exchange offering subject to SEC
registration.
•Explain how you concluded that GTB tokens held for trading may be characterized as
intangible assets.  Refer us to your basis in the accounting literature.
•Compare for us your total GTB holdings, including those which are denominated in
Bitcoin and Ether, to the total GTB circulating supply based on information available
through Asia EDX and GT Dollar.
•Explain if and when you will be able to exchange your GTB tokens denominated in
Bitcoin and Ether into other digital currencies.  Since your holdings of GTB tokens
denominated in Bitcoin and Ether do not constitute direct holdings of such currencies,
please explain to us how the GTB/BTC and GTB/ ETH conversion ratios (per your
supplementary materials) were determined and when and how such denominations
may be converted into direct holdings.  Further clarify if settlement of the exchange
transaction is the subject of a futures or forward contract.
•Tell us if you may be deemed a broker/dealer of GTB tokens or a money services
business (i.e., an administrator of the GTD blockchain) subject to securities and
commodities, money services and transmitter laws which you referenced on pages
78-79 of your filing.  Please provide us a detailed evaluation of your capacity to
distribute and trade GTB tokens in this regard.
Note 1. Nature of Operations and Summary of Significant Accounting Policies
Digital Currency, page F-47
3.We note your response to comment 6.  Please expand your disclosure to identify the
applications that are currently functional on the GTD block chain and the extent to which
GTB token holders have utilized their token holdings to access such applications.  Clarify
your disclosure to state whether Asia EDX allows such holders to access and use their
GTB tokens in exchange for goods and services sold by participating merchants, absent
any ability to convert such tokens into fiat.

 FirstName LastNameAlfred  Poor
 Comapany NameIdeanomics, Inc.
 January 27, 2020 Page 3
 FirstName LastName
Alfred  Poor
Ideanomics, Inc.
January 27, 2020
Page 3

Note 6. Accounts Receivable, page F-51
4.We note that you sold your Amer subsidiary which had accounted for a significant portion
of your uncollected long-term receivables through August 31, 2019.  Please tell us your
consideration of the Amer subsidiary as a discontinued operation pursuant to ASC 205-
20-45-1(B)(b).  In this regard, we note that your ongoing operations appear to constitute a
significant strategic shift from your former trading business in 2018.
General
5.We note your Form 8-K filing on January 10, 2020 discussing a letter from Nasdaq's
listing qualifications staff regarding the company's compliance with certain listing
standards.  Please prominently disclose and discuss these developments in your
prospectus.
            You may contact Kathryn Jacobson, Senior Staff Accountant at (202) 551-3365 or Robert
Littlepage, Accountant Branch Chief at (202) 551-3361 if you have questions regarding
comments on the financial statements and related matters.  Please contact William Mastrianna,
Staff Attorney at (202) 551-3778 or Celeste Murphy, Legal Branch Chief at (202) 551-3257 with
any other questions.
Sincerely,
Division of Corporation Finance
Office of Technology
cc:       William N. Haddad