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CORRESP
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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

Paul Fischer

Celeste Murphy

Re: Ideanomics,
Inc.

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

Form 10-Q for the
Quarter Ended September 30, 2019 Filed November 14, 2019

Response Letter
Dated January 9, 2020

File No. 001-35561

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 29, 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 10-Q for the Quarter Ended September
30, 2019

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

Digital Currency, page 10

1. 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.

In response
to this comment the Company has expanded its disclosure in the Form S-1/A filed on February 5, 2020 to include reference to GTB
being used to pay for purchases at participating merchants. The Company will include such disclosure in future filings on Form
10-Q and 10-K. The updated disclosure is included on page F-47 — Digital Currency.

Note 5. Acquisitions and Divestitures

(h) Amer Global Technology Limited
("Amer"), page 17

2. It appears that Amer may be deemed
a discontinued operation as your ownership interest was diluted to 0% as of August 31, 2019 and you no longer are involved in
the consumer electronics trading business. Accordingly, please revise your presentation and related disclosures as appropriate.
Refer to ASC 205-10-15-2, ASC 205-20-451B(b), and ASC 205-20-50-5

We assume that your reference to 0% in
the above paragraph was intended to reference the Company’s holding in Amer of 10%

At the time of disposal of the Company’s
majority ownership interest in Amer consideration was given as to whether Amer should be considered a discontinued operation.
In accordance with the guidance, the Company believes that Amer should not be considered a discontinued operation as the disposal
does not represent a strategic shift away from the Company’s business strategy of seeking opportunities to deploy blockchain
and AI technologies to disrupt established industries and business processes. The Company has been consistent in its disclosure
that Amer was purchased as a means of learning about the consumer electronics industry with the goal of identifying opportunities
to deploy blockchain in a disruptive manner. The Company disposed of Amer because it believes that it had extracted most of the
learnings to be had through majority ownership. Please see page 34 of the Company’s 10-Q filing for the period ended September
30, 2018 and page 3 of the 10-K filing for the Year Ended December 31, 2018 for discussion of the rationale for the Company’s
investment in Amer.

Overview, page 32

3. We understand from your disclosure
elsewhere in your filing 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.”

• 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 c