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Ideanomics, Inc.

55 Broadway, 19th
Floor

New York, NY 10006

February 5, 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

Filed on December
31, 2019

File No. 333-224382

Dear Mr. Littlepage
and Ms. Jacobson:

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 January 27, 2020
(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 S-1 filed on 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.

We have updated the Offering section at page 10 of the S-1/A
to address the Staff’s comment.

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 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.

In considering The
Company’s response to the Staff’s comments the following overview of the Company’s activities in blockchain
and related technologies maybe helpful.

The Company has
a stated business goal to identify and deploy blockchain applications where it sees commercially viable opportunities to disrupt
established industries and business processes.  The Company’s investment in Amer and Sun Seven Stars Energy were efforts
to learn about the markets and business processes in the electronic components and oil industries, respectively. Similarly, the
Company’s Digital Asset Management Services Agreement with GT Dollar (GTD) was also part of this type of initiative.
For clarity, in its provision of services under the Digital Asset Management Services Agreement, the Company provided consulting
advice on the deployment of blockchain and Artificial Intelligence (AI) technologies on the GTD blockchain platform. The Company
was not, and is not, involved in the management or operation of the GTD platform.   As referenced
on p. 78 of the Company’s S-1/A filed on December 31, 2019, the Company believes that there is potential to use blockchain
technology to create and trade digital securities referred to as digital tokens; however, the Company has not commenced
this activity. If and when the Company engages in such activity it anticipates using its FINRA registered Broker Dealer, The Delaware
Board of Trade (DBOT) and its registered Alternative Trading System (ATS) as the platform for distributing and trading digital
securities, subject to having obtained all necessary regulatory approvals and licenses.

Separately,
and unrelated to the blockchain and digital token business objectives discussed above, the Company holds GTB cryptocurrency (GTB).
The Company is a passive holder of GTB with the stated intention of converting the GTB into fiat as quickly as possible,
subject to market conditions.  It is not the Company’s intention in any way to trade the GTB in an attempt
to profit from changes in the market price.  The Company received the GTB simply as payment for content that it sold to GTD
and as payment for services performed by the Company for GTD under the Digital Asset Management Services Agreement discussed above
and has been making efforts only to convert the GTB to fiat.  In the absence of the AsiaEDX exchange permitting the conversion
of GTB to fiat, the Company has converted a portion of its holdings of GTB into the more widely traded and liquid Bitcoin (BTC)
and Ethereum (ETH) in an effort to make the Company’s holding of cryptocurrency less subject to volatile price movements.
The Company will update its disclosures in future Form 10-K and Form 10-Q filings in a manner similar to those disclosures
contained in the Form S-1/A filed on February 5, 2020 in order to clarify that the value of the Company’s holdings of BTC
 & ETH are subject to changes in the price ratio of GTB to US$ rather than the quoted price of BTC & ETH.

• 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.

As
stated above, the Company is a passive holder of GTB with the stated intention of converting the GTB into fiat as
quickly as possible, subject to market conditions.  It is not the Company’s intention in any way to trade
the GTB in an attempt to profit from changes in the market price.  The Company received the GTB simply as payment for content
that it sold to GTD and as payment for services performed by the Company for GTD under the Digital Asset Management Services Agreement
discussed above and has been making efforts only to convert the GTB to fiat. As referenced on p. 78 of the Company’s
S-1/A filed on December 31, 2019, the Company believes that there is potential to use blockchain technology to create and trade
digital securities referred to as digital tokens; however, the Company has not commenced this activity. The Company will
only commence this activity once a regulatory framework is in place and in compliance with such regulatory framework. In the absence
of the AsiaEDX exchange permitting the conversion of GTB to fiat, the Company has converted a portion of its holdings of GTB into
the more widely traded and liquid Bitcoin (BTC) and Ethereum (ETH) in an effort to make the Company’s holding of cryptocurrency
less subject to volatile price movements.  The Company will update its disclosures in future Form 10-K and Form 10-Q
filings in a manner similar to those disclosures contained in the Form S-1/A filed on February 5, 2020 in order to clarify that
the value of the Company’s holdings of BTC & ETH are subject to changes in the price ratio of GTB to US$ rather than
the quoted price of BTC & ETH. Based upon the foregoing and the fact that the Company is not acting as a speculator or investor
intending to make or lose money from buying and selling GTB, the Company does not believe that whether the GTB tokens are deemed
a security is relevant.

• 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.

As explained above, the Company is not
now, nor was it ever in the past, distributing GTB tokens. The Company is a passive holder of GTB, Bitcoin and Ethereum
with the sole objective of converting these holdings to fiat. The Company’s conversion of GTB into Bitcoin and Ethereum
was done solely as an effort to reduce volatility and market risk by converting a portion of the Company’s holdings of GTB
to Bitcoin and Ethereum which are more liquid and normally less volatile in terms of price change. The Company will update its
disclosures in future Form 10-K and Form 10-Q filings in a manner similar to those disclosures contained in the Form S-1/A filed
on February 5, 2020 in order to clarify that the value of the Company’s holdings of BTC & ETH are subject to changes
in the price ratio of GTB to US$ rather than the quoted price of BTC & ETH.

• 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.

As explained above,
the Company does not hold GTB, Bitcoin or Ethereum for the purposes of trading the holdings. The Company is a passive
holder of GTB, Bitcoin and Ethereum with the sole objective of converting these holdings to fiat.

Below is the relevant
extract from the Company’s accounting memo related to its holdings of GTB. The full memo was provided as an Appendix to
the Company’s response on January 15, 2020 to the previous comment letter on the S-1 filing

“Given
that there is limited precedent regarding the classification and measurement of cryptocurrencies and other digital tokens under
current Generally Accepted Accounting Principles (“GAAP”), the Company has determined to account for these tokens
as indefinite-lived intangible assets by reference to the existing International Financial Reporting Standards (“IAS 38”)
and apply analogy to ASC 350, Intangibles—Goodwill and Other until further guidance is issued by the FASB because:

 a. it
                                         is a resource controlled by an entity (that is, the entity has the power to obtain the
                                         economic benefits that the asset will generate and to restrict the access of others to
                                         those benefits) as a result of past events and from which future economic benefits are
                                         expected to flow to the entity;

 b. it
                                         is identifiable, because it can be sold, exchanged or transferred individually;

 c. it
                                         is not cash or a non-monetary asset; and

 d. it
                                         has no physical form.

Therefore,
we recorded GTB tokens at cost and not subject to amortization, but shall be tested for impairment annually and more frequently
if events or changes in circumstances indicate that it is more likely than not that they are impaired. If, at the time of an impairment
test, the carrying amount of an intangible asset exceeds its fair value, an impairment loss in an amount equal to the excess is
recognized in the statement of operations.”

As discussed on
a conference call with the SEC staff on January 29, 2020, the Company has included disclosure regarding the impairment of GTB
tokens in the “Recent Developments” section of the Form S-1/A filed with the SEC on February 5, 2020.

• 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.

The Company has
been unable to find information regarding the total GTB circulating supply from any source including 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.

The AsiaEDX currently
permits holders of cryptocurrencies on the exchange to convert holdings between the various cryptocurrencies traded on the exchange.
The AsiaEDX exchange currently does not permit the conversion of cryptocurrencies into fiat. The Company’s disclosure in
its most recently filed S-1/A on December 31, 2019 includes disclosures relating to the inability of the Company to convert its
holdings of GTB, BTC and ETH into fiat – see the Overview on page 37 and Note 19, “Concentration, Credit and Other
Risks” subsection (f) “Digital Currency Risks” on page F-64.

Conversions of cryptocurrencies
quoted on the AsiaEDX platform are executed at the rates quoted on the platform at the time of exchange / conversion. The company
has no control over the quoted rates. The settlement of exchange transactions does not require nor result in a futures or forward
contract.

The Company will
update its disclosures in future Form 10-K and Form 10-Q filings in a manner similar to those disclosures contained in the Form
S-1/A filed on February 5, 2020 in order to clarify that the value of the Company’s holdings of BTC & ETH are subject
to changes in the price ratio of GTB to US$ rather than the quoted price of BTC & ETH.

• 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.

As stated above,
the Company is a passive holder of GTB with the stated intention of converting the GTB into fiat as quickly as possible,
subject to market conditions.  It is not the Company’s intention in any way to trade the GTB in an attempt
to profit from changes in the market price.  The Company received the GTB simply as payment for content that it sold to GTD
and as payment for services performed by the Company for GTD under the Digital Asset Management Services Agreement discussed above
and has been making efforts only to convert the GTB to fiat.  In the absence of the AsiaEDX exchange permitting the conversion
of GTB to fiat, the Company has converted a portion of its holdings of GTB into the more widely traded and liquid
Bitcoin (BTC) and Ethereum (ETH) in an effort to make the Company’s holding of cryptocurrency less subject to volatile price
movements.  The Company has no intention at all nor does it possess any capacity at all distribute and trade tokens. Based
upon the foregoing, the Company does not believe that it could be deemed in any way a broker/dealer of GTB tokens or a money services
business subject to relevant law. As referenced on p. 78 of the Company’s S-1/A filed on December 31, 2019, the Company
believes that there is potential to use blockchain technology to create and trade digital securities referred to as digital tokens;
however, the Company has not commenced this activity. If, in the future, the Company decides to commence this activity
it will only do so once all the necessary regulatory approvals and licenses have been obtained. Subject to any regulations then
in place, the Company anticipates using its FINRA registered Broker Dealer, The Delaware Board of Trade (DBOT) and its registered
Alternative Trading System (ATS) as the platform for distributing and trading digital securities and tokens in the event that
the Company is able to create any digital securities.

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 acces