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Ideanomics, Inc.

55 Broadway, 19th Floor

New York, NY 10006

January 15, 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

Celeste Murphy

Paul Fischer

Re: Ideanomics, Inc.

Registration Statement on Form S-1/A

File No. 333-224382

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 August 9, 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.

Registration Statement on Form S-1/A, filed on August 2,
2019

We are subject to risks related to holding cryptocurrencies
and accepting cryptocurrencies as a form of payment., page 21

 1. Please revise your risk factor to address other potential
risks related to holding the GTB cryptocurrency you received in March, 2019, including risks related to the storage or custody
of the private key(s) granting access to the digital assets, such as the threat of a cybersecurity breach, as well as potential
risks created by events on the underlying blockchain, such as "forks" and "airdrops." Please also discuss
either here or in another part of your prospectus your current storage and custodial practices with respect to the GTB cryptocurrency.

The risk factor was updated in our S-1 A 4th Amendment filed
on December 31, 2019 to address the above comments

 2. We note your statement in paragraph two that you "currently expect to hold [y]our GTB unless you need cash to support
your operations, at which time you may determine to convert to fiat currency and U.S. dollars." With a view towards disclosure,
please advise what consideration you gave to the inclusion of risk factor disclosure addressing the possible need to register as
an investment company under the Investment Company Act.

We do not consider it likely that we will need to register as
an investment company. Under Section 3(b)(1) of the 1940 Act, an issuer is not an investment
company if it is primarily engaged, directly or through wholly-owned subsidiaries, in a business other than that of investing,
reinvesting, owning, holding or trading in securities, we believe that Ideanomics meets this criteria. Furthermore, we believe
that we meet the five principal factors set-out in Tonopah Mining Co. for determining an issuer’s "primary
business" under Section 3(b)(2) and that applying these factors supports our position that Ideanomics is not an investment
company. We will continue to monitor our business in the context of the Investment Company Act.

Overview, page 36

 3. In light of your significant holdings of GTB tokens, please describe in your MD&A overview your plan to monetize these
tokens.

The MD&A has been updated at page 37 of the S-1A filed on
December 31, 2019 to address the above comment.

Comparison of Three Months Ended March 31, 2019 and 2018
Selling, general and administrative Expenses, page 42

 4. We note that on February 12, 2019, you entered into separate covenants not to sue with certain individuals. Please disclose
the significant terms of these agreements, including but not limited to payable consideration of $800,000 in the aggregate, and
how you accounted for them in the financial statements. Refer to Exhibits 10.11, 10.12, and 10.13 of the Form 10-Q filed on May
2, 2019 and the Form 8-K filed on February 26, 2019.

The MD&A in the Form 10-Q filing for the period ending September
30, 2019 has been updated to address the above comment and has also been included in the S-1A filed on December 31, 2019 to address
the above comment.

Legal Matters, page 106

 5. We note that Sherman & Howard will pass upon the validity of the shares you are offering pursuant to the registration
statement, however see no Exhibit 5.1 in your Exhibits list.

Please file counsel's opinion as an
exhibit to your filing prior to requesting effectiveness, allowing sufficient time for staff review. Please refer to Item 601(b)(5)(i)
of Regulation SK.

We will file the legal opinion when the
S-1A is ready to go effective, allowing sufficient time for staff review.

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

Digital Currency, page F-47

 6. We note that GTB "is not backed by hard assets
or other financial instruments and does not represent an investment in GTD or a right to access GTD's platform." If so, please
help us reconcile this disclosure with your March 19, 2019 press release which reported that GT Dollar has been underwriting its
tokens with asset-backed collateral, including real estate, airlines, insurance as well as regional bank clearance and acceptance,
to launch consumer loyalty programs for those using GT Dollar when it initially launched." Refer to your press release at
https://www.prnewswire.com/newsreleases/ ideanomics-signs-digital-asset- management-services-agreement-withsingapores-gt-dollar-and-thai-setaku-insurance-
300814769.html.

The press release was describing the GT Dollar (GTD) entity’s
operating model as we understood it. GTB refers to the cryptocurrency that runs on the GTD block chain. Holders of GTB have the
right to access applications that run on the GTD block chain but do not have an ownership interest in GTD or the rights to access
or use its block chain other than for approved applications. For example, the GTD block chain has a payment application that allows
holders of GTB to purchase and pay for goods and services from participating merchants – we understand that some taxi cabs
and coffee shops in Singapore accept payment in GTB – however access to the payment application does not confer any rights
to GTD

Additionally, it does not appear that Asia EDX
Exchange (Https://asiaedx.com) has a functioning website or that it is operational. Please advise
us.

We have been able to interact with the Asia EDX website, however
there does appear to be a number of dead or inoperative links.

 7. We also note per Exhibit 10.14 of the Form 10-Q filed May 2, 2019 that Thai Setaku Insurance is a counterparty to your Service
Agreement with GT Dollar. Please disclose its role and its respective rights and obligations in connection with the subject agreement.

The business plan for GTB included a product (DICA) which can
most easily be described as a form of cash back plan for purchases made with GTB, similar in nature to the ones offered by credit
card companies. The DCIA cash back program would have operated using an investment fund with consumers who used GTB for purchases
getting a periodic dividend, paid in GTB proportionate to their purchases. If the DICA product had been marketed as originally
envisaged the fund underlying the DICA would have been underwritten by Thai Setaku Insurance. The DCIA product has not been marketed
and consequently the services of Setaku Thai Insurance have not been used.

 8. Please tell us and disclose how you adjusted the Black-Scholes option pricing model to value the GT tokens. Also, please
disclose how you determined the surrogate inputs to the model such as the option strike price and the current stock price.

Due to the limited trading history and the existence of a singular
currency exchange platform, the Company determined that GTB tokens contained a lack of marketability. Therefore, the Company used
a Black-Scholes Option Pricing Method (“BSOPM”) that is used to estimate a discount for lack of marketability (“DLOM”)
in connection to the restricted common stock of a public company that must be held (not traded) until a given holding period lapses.
At the end of the holding period, the trading restrictions on the stock lapse and the shares revert to an unrestricted, freely-traded
basis (so called Put Option Model). In the Put Option Model, the key drivers of the DLOM are the stock price volatility ratio and
the holding period term. We calculated the volatility of GTB tokens for the period since inception to April 29, 2019 and estimated
the holding period as 3 years (since the contract’s service period with GTD is 3 years for exclusive marketing services).
The implied DLOM is 61% (Please see Exhibit A). We further considered that we also need to consider the volatility of BTC or ETH.
Therefore, we estimated volatility for both GTB tokens and BTC/ETH is 155% and the implied DLOM is 76%. For the purposes of the
BSOPM, the Company assumed an at the money option with a stock price of $1

 9. Please disclose in greater detail the nature of the GT digital currency. Clarify whether a GTB token as referenced in your
response is the same as a GT token as referenced in your service agreement. Also, disclose whether it is convertible into a fixed
or variable amount of conventional currency and whether you will be able to use it freely in commerce in exchange for goods and
services, both within and away from the GT Dollar platform.

GT digital currency (“GTB”) is a type of digital
asset traded on the Asia EDX exchange. We believe GTB was created as an alternative to fiat currency as a vehicle to transfer value.
GTB is not a fiat currency and is not backed by hard assets or other financial instruments. GTB does not represent an investment
in GT Dollar Pte. Ltd. (“GTD”) or a right to access GTD’s platform. As a result, 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;
however, we are not aware of any observable transactions in which GTB has been bought or sold in exchange for cryptocurrencies
or fiat currency. To date, the Asia EDX exchange has not permitted holders of GTB, Bitcoin or Ethereum to convert digital currencies
held in accounts at the Asia EDX exchange for fiat currency. The Company is unable to predict when its GTB will be convertible
into fiat and consequently does not consider GTB to be part of the Company’s liquid resources.

Note 6. Accounts Receivable, page F-51

 10. Considering that most of your receivables exceed 180 days, please tell us why you have experienced significant payment delays
and what amounts you received (if any) subsequent to your first quarter. Tell us whether contract provisions limit your exposure
to credit risk and whether you have an enforceable right to payment. If not, tell us the factors you considered in determining
their collectability apart from oral promises.

The payment delays were related to receivables owed to our Amer
subsidiary which were caused by the banks closing of the accounts held by Amer with that institution. We were assured that the
receivables would be paid once Amer opened a new bank account. As stated in our response of December 5, 2019 to the Staff’s
letter dated October 16, 2019, 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.

Note 12. Convertible Note, page F-55

 11. We note in the last paragraph that IDV has registration rights that require the Company to file and register the common
stock issued or issuable upon conversion of the convertible note or the exercise of the warrants, within 180 days following the
closing of the transaction. Please clarify

• what constitutes an event of default pursuant
to the note indenture,

An Event of Default requires an occurrence of one of the defined
Events of default - see attached Appendix A for full details of the Events of Default – and a declaration by
the note Holder under Section 8 (b) that an Event of Default has occurred. The note holder did not call a Default under Section
8. (b). The Company has a long relationship with the note holder ID Venturas 7 LLC and is in continuing contact with them.

• whether such default triggers cross defaults
in your other note agreements, and

A Default in relation to the failure to
file and register the common stock would not constitute a Default under the other outstanding notes.

• what remedies do the note holders have,
if any, in connection with each default.

The remedies for a Default are set out
in Section 1. Definitions under Mandatory Default Amount, the full text of the definition is included in Appendix A. To summarize,
the Mandatory Default Amount requires immediate repayment of all monies due under the note.

Note 14. Related Party Transactions

(b) Transactions with GTD

Disposal of Assets in exchange of GTB, page F-57

 12. Tell us how to reconcile the significant variance between the resultant value of $3.76 per token in the revenue arrangement
and $16.32 per token received in the non-monetary exchange. In this regard, we note that you received the tokens in connection
with contemporaneous transactions involving the same counterparty.

Additionally, tell us the third party valuation
report's basis for its expected cash flows assumptions underlying the income approach which it used to determine the fair value
of the licensed content. In this regard, we note that you have not earned income or generated cash flows from such license during
the past two years.

The attached Accounting Memo prepared for the GTD transactions
provides the most complete response to the staff’s question.

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

Appendix A

ID Venturas 7 LLC – Note maturing August 22, 2020
 – extract of provisions relating to Default

Section 8 Events of Default

    a) “Event of Default” means, wherever used herein, any of the following events (whatever the reason for such event and whether such event shall be voluntary or involuntary or effected by operation of law or pursuant to any judgment, decree or order of any court, or any order, rule or regulation of any administrative or governmental body):

    i. any default in the payment of (A) the principal amount of any Debenture or (B) interest, liquidated damages and other amounts owing to a Holder under any Debenture, as and when the same shall become due and payable (whether on a Conversion Date, Optional Redemption Date, or the Maturity Date or by acceleration or otherwise) which default, solely in the case of a default under clause (B) above, is not cured within three (3) Trading Days;

    ii. the Company shall fail to observe or perform any other covenant or agreement contained in the Debentures (other than a breach by the Company of its obligations to deliver shares of Common Stock to the Holder upon conversion, which breach is addressed in clause (xi) below) or in any Transaction Document, which failure is not cured, if possible to cure, within the earlier to occur of (A) ten (10) Trading Days after notice of such failure sent by the Ho