SecProbe.io

CORRESP
1
filename1.htm

Ideanomics, Inc.

55 Broadway, 19th Floor

New York, NY 10006

January 9, 2020

U. S. Securities and Exchange Commission

Division of Corporate Finance

100 F Street, N.E.

Washington D.C., 20549

Attention: Kathryn Jacobson

Robert Littlepage

Paul Fischer

Celeste Murphy

Re: Ideanomics, Inc.

Form 10-K for the Year Ended December 31, 2018 Filed April
1, 2019

Form 10-Q/A for the Quarter Ended March 31, 2019 Filed July
16, 2019

Form 10-Q for the Quarter Ended June 30, 2019 Filed August
14, 2019

File No. 001-35561

Dear Mr. Fischer and Ms. Murphy:

On behalf of Ideanomics, Inc., a Nevada corporation (the “Company”),
we submit this letter in response to comments received from the staff (the “Staff”) of the Securities and Exchange
Commission (the “Commission”) by letter on October 16, 2019 (the “Comment Letter”) with respect to the
Company’s above referenced Forms.

For the convenience of the Staff, the numbering of the
paragraphs below corresponds to the numbering of the comments in the Comment Letter, the text of which we have incorporated
into this response letter for convenience in italicized type and which is followed by the Company’s response. In the
responses below, page number references are to the Registration Statement.

Form 10-Q/A for Quarter Ended March 31, 2019

Item 2. Management’s Discussion & Analysis of
Financial condition and Results of Operations

Selling, general and administrative expenses, page 33

We note your response to comment seven and the disclosure
provided in Note 13(d).

Please clarify in MD&A where in your income statement
you reported the $837,000 in

total salary, severance and other expenses, and advise us.

In response to the Staff’s comment, the severance expense
of $837,000 was recorded in SG&A expense. We have updated the MD&A in our Form 10-Q filing for the period ended September
30, 2019 to include an explicit reference to this expense.

Form 10-Q/A for Quarter Ended June 30, 2019

Note 1. Nature of Operations and Summary of Significant Accounting
Policies

Digital Currency, page 11

2.       We note your
response to comments one and four and your disclosure here under that GTB holders have "the right to access the applications
built with GTD Payment Blockchain." In your response to prior comment six in your letter dated July 16, 2019,you stated that
 "ownership of GTB does not represent a right to access GD's platform." Please help us reconcile the inconsistencies
in your statements.

Ownership of GTB provides holders with the right to access
applications built within the GTD Payment Blockchain environment. Such applications include software services built on the GTD
Payment Blockchain environment.

The response in our letter dated July 16, 2019 further clarifies
that GTB ownership does not provide holders with rights or access to the underlying GTD Payment Blockchain codebase nor the ability
to make any modifications to the GTD Payment Blockchain or platform via other means. Holders of GTB have access to applications
built on the GTD blockchain but not to the blockchain itself. For example the GTD blockchain has a payment application through
which holders of GTB can pay for goods and services at participating merchants, we understand that some small retailers located
in Singapore will accept GTB as payment.

3.       With respect
to your disclosure regarding the conversion of 785,786 GTB to 2,409 Bitcoins and 17,460 Ethereum, please

• disclose your basis for determining the
values of the digital currencies and any resultant gain or loss;

The values of GTB denominated Bitcoins and GTB denominated
Ethereum are based on the market price provided by the Asia EDX exchange on the date of each transaction, net of transaction costs
paid to the Asia EDX exchange. The value of GTB denominated Bitcoins and GTB denominated Ethereum is equal to the cost basis
of the GTB prior to conversion  . The Company accounted for the conversion
as a nonmonetary transaction, and there was no gain or loss recognized on the conversion. As of September 30, 2019, the value
of GTB denominated Bitcoins (BTC) was $23,058,645.52 , and the value of GTB denominated Ethereum
(ETH) was $3,779,466.

• explain the means, process and methods
by which the exchanges were initiated and effected in great detail;

The exchanges were initiated via the Asia EDX exchange, where
Ideanomics, Inc. has an account. The conversion of GTB took place over the period April 3, 2019 thru November 4, 2019 in order
to minimize the impact on price fluctuation in the Asia EDX exchange. During a portion of the conversion period, the Asia EDX
exchange instituted a maximum daily GTB conversion of CNY ¥200,00 (based on the market price provided by the Asia EDX exchange),
which further restricted the rate of conversion; this cap has since been removed. Ideanomics, Inc. utilized the Asia EDX exchange
to post sell offers and match with buyers via the open market.

The operational process followed to execute a conversion on
the Asia EDX exchange is as follows

 · The company holds its GTB in a GTD wallet. When we want to convert GTB to BTH & ETH a transfer is made from the GTD wallet
to the Asia EDX exchange.

 · All conversion transactions are executed on the Asia EDX exchange

 · One employee is designated with the day to day operational responsibility for GTB

 · This employee had a standing instruction to convert on a regular basis, normally daily, an amount of GTB into BTC & ETH.
Management would periodically change the amount to be converted. No conversion
trades have been executed since November 4, 2019 as management considered the exchange rate between GTB and BTC & ETH to be
unfavorable.

 · The employee signs in on their company laptop and initiates the daily conversion in the amounts agreed. Sign-in is by way of
a typical username and password combination.

 · Once the conversion trades have been initiated, the employee brings their laptop to the corporate controller who enters the
corporate password for the Company’s account on the Asia EDX exchange and approves the transaction.

 · At the end of each day the corporate controller reviews the movements on the company’s account and confirms that all
activity is authorized and valid.

• identify your subsidiary and its major
counter parties in the exchange transactions, as well as their respective locations if known; and

Ideanomics, Inc. entered into the exchange transactions via
the Asia EDX exchange, and counterparties were matched via the exchange’s matching engine. As part of each transaction,
the Asia EDX exchange was paid a fee deducted from the assets converted. The major counterparties to the Company in the exchange
transactions and their respective locations are not known. No consolidated subsidiaries of Ideanomics, Inc. were party to this
exchange, or any transactions, conversions, or holding of GTB.

• how such counterparties will be able to
monetize and distribute their GTB holdings.

As noted in Item 1A. Risk Factors of our September 30, 2019
10-Q, the Asia EDX exchange has not permitted us to convert any part of our holdings of GTB, Bitcoin & Ethereum to fiat. The
Asia EDX exchange is, to date, the only cryptocurrency exchange currently making markets for GTB and does not currently offer
fiat pairs to any user. We are in regular contact with the Asia EDX exchange regarding the ability to convert some or all of our
holdings to fiat, and we have been informed that the exchange plans to introduce a capability to allow convertibility into fiat.
It is possible that the Asia EDX exchange may never allow GTB, Bitcoin & Ethereum held at the exchange to be converted into
fiat or it may take an extended period of time to convert GTB, Bitcoin & Ethereum to fiat.

In addition, because converting our holdings to fiat currency
will likely take an extended period of time, if the Asia EDX exchange were to cease operations or no longer quote GTB, there would
be no trading platform for GTB, and it would likely be impossible to convert GTB into fiat currency.   Additionally,
on page 19 of our September 30, 2019 10-Q in the Notes to Unaudited Consolidated Financial Statements in the section dealing with
Digital Currency we included the following sentence – “The company is unable to predict when our cryptocurrency holdings
will be convertible into fiat and consequently does not consider them to be part of the company’s liquid resources”

4.       We note your
statements that GTB has been actively trading on Asia EDX Exchange. Please provide us a year-to-date trading history of GTB on
the Asia EDX Exchange, including as of each trading date, its price (open, high, low, close), volume, its circulating supply,
and market cap. Include a link to an independent third party which contains the requested information.

The Asia EDX exchange does not offer historical pricing or trade
history via its website (https://www.asiaedx.com/#/). The requested information is not provided from an independent third party.
In order to maintain appropriate books and records.  Ideanomics, Inc. maintains a price history file of the daily GTB/BTC price
sourced from the Asia EDX exchange, including the open, high, low, close, and volume for each day. 10pm EST was used as the close
time, as the Asia EDX exchange does not close. These files are attached.

Note 5, Accounts Receivable, page 15

We note your response to comment five. On page 26, under
Concentration of Credit Risks, you disclosed that as of June 30, 2019 and December 31, 2018, the Company's cash was held by financial
institutions (located in the PRC, Hong Kong, the United States and Singapore). It is unclear to us why the closing and reopening
of any one bank account can affect certain customers' ability to pay. Tell us why the subject bank account was closed, why you
are experiencing a delay in reopening it, and why your customers' payments cannot be diverted to any of the other bank accounts.
Additionally, tell us in detail what your options are in connection with your right to enforce payment.

In response to the Staff’s comment, Amer was a joint venture
in which Ideanomics’ owned 55% of the equity and had control of the Board. Given that Amer was a joint venture, rather than
a wholly owned subsidiary, it was determined that having another Ideanomics’ entity receive the cash on behalf of Amer would
potentially give rise to tax and regulatory reporting issues and consequently it was decided not to pursue the option of having
customer payments sent to a bank held by another entity in the Ideanomics corporate structure.

The Amer subsidiary was sold on August 31, 2019. The disposal
was disclosed in note 5 (h) in our Form 10-Q filing for the quarter ended September 30, 2019.

Should you have any further questions or comments regarding
the captioned filings and/or this letter, please direct them to me at (212) 206-1216 or William N. Haddad, Esq. of Venable LLP,
counsel to the Company at (212) 503-9812.

    Very truly yours,

    /s/ Alfred Poor

    Alfred Poor

    Chief Executive Officer

 cc: William N. Haddad, Esq., Venable LLP