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SEC Company Response from IDEANOMICS, INC. (CIK 0000837852) (IDEXQ) — Mar 26, 2020

IDEANOMICS, INC. (CIK 0000837852)
Date: March 26, 2020 · CIK: 0000837852 · Accession: 0001104659-20-038978

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File numbers found in text: 333-237251

Date
March 26, 2020
Author
Alfred Poor
Form
CORRESP
Company
IDEANOMICS, INC. (CIK 0000837852)

Letter

IDEANOMICS, INC.

55 Broadway, 19th Floor

New York, NY 10006

March 26, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

Re: Ideanomics, Inc.

Registration Statement on Form S-3

Filed March 18. 2020

File Number 333-237251

REQUEST FOR ACCELERATION OF EFFECTIVENESS

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities Act of 1933, as amended, Ideanomics, Inc. (the “Company”) hereby respectfully requests acceleration of the effectiveness of the Company’s Registration Statement on Form S-3, File Number 333-237251, so that it will be declared effective on Monday March 30, 2020 at 9:00 a.m. Eastern Time, or as soon as practicable thereafter.

This letter will confirm that the Company acknowledges that:

• should the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

• the action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

• the Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission or any person under the federal securities laws of the United States.

Please contact our legal counsel, William N. Haddad, of Venable LLP, at (212) 503-9812, if you have any questions concerning this request.

Very truly yours,
Ideanomics, Inc.

Show Raw Text
CORRESP
1
filename1.htm

IDEANOMICS,
INC.

55 Broadway, 19th Floor

New York, NY 10006

March 26, 2020

VIA EDGAR

U.S. Securities and Exchange Commission

Division of Corporation Finance

100 F. Street, N.E.

Washington, D.C. 20549

 Re: Ideanomics,
Inc.

Registration
Statement on Form S-3

Filed
March 18. 2020

File
Number 333-237251

REQUEST
FOR ACCELERATION OF EFFECTIVENESS

Ladies and Gentlemen:

In accordance with Rule 461 under the Securities
Act of 1933, as amended, Ideanomics, Inc. (the “Company”) hereby respectfully requests acceleration of the effectiveness
of the Company’s Registration Statement on Form S-3, File Number 333-237251, so that it will be declared effective on Monday
March 30, 2020 at 9:00 a.m. Eastern Time, or as soon as practicable thereafter.

This letter will confirm that the Company
acknowledges that:

 • should
the Securities and Exchange Commission (the “Commission”) or the staff, acting pursuant to delegated authority, declare
the filing effective, it does not foreclose the Commission from taking any action with respect to the filing;

 • the
action of the Commission or the staff, acting pursuant to delegated authority, in declaring the filing effective, does not relieve
the Company from its full responsibility for the adequacy and accuracy of the disclosure in the filing; and

 • the
Company may not assert staff comments and the declaration of effectiveness as a defense in any proceeding initiated by the Commission
or any person under the federal securities laws of the United States.

Please contact our legal counsel, William
N. Haddad, of Venable LLP, at (212) 503-9812, if you have any questions concerning this request.

    Very truly yours,

    Ideanomics, Inc.

    By:
    /s/ Alfred Poor

    Name:
    Alfred Poor

    Title:
    Chief Executive Officer