Correspondence 0001104659-23-005249 from IDEANOMICS, INC. (CIK 0000837852) (IDEXQ)
IDEANOMICS, INC. (CIK 0000837852)
Date: Jan. 20, 2023 · CIK: 0000837852 · Accession: 0001104659-23-005249
AI Filing Summary & Sentiment
Reasoning
File numbers found in text: 333-269001
Referenced dates: January 19, 2023
Letter
T 212.503.9812
F 212.307.5598
wnhaddad@venable.com
January 20, 2023
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing
100 F Street, N.E.
Washington, DC 20549
Attention: Eranga Dias
Asia Timmons-Pierce
Re: Ideanomics, Inc.
Registration Statement on Form S-1
Filed December 23, 2022
File No. 333-269001
Ladies and Gentlemen:
On behalf of our client, Ideanomics, Inc. (the “Company”), we submit this letter setting forth the responses of the Company to the comments provided by the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission in its comment letter dated January 19, 2023 (the “Comment Letter”) with respect to the above-referenced Registration Statement on Form S-1 (“Registration Statement”). In response to the Comment Letter, the Company is filing Amendment No. 1 to the Registration Statement (the “Amended Registration Statement”) through EDGAR.
For your convenience, we have set forth each comment of the Staff from the Comment Letter in bold type below followed by the Company’s response thereto.
Registration Statement on Form S-1 Filed 12/23/2022
Cover Page
1. Please disclose that you have received a notice from Nasdaq indicating that the company was no longer in compliance with the audit committee requirements as set forth in Nasdaq Listing Rule 5605. Please provide an update on the status of this notice. Please also disclose the status of the notice of non-compliance with the Nasdaq requirements pertaining to the minimum bid price for listed stock pursuant to Nasdaq Listing Rule 5550(a)(2). Please also add risk factor disclosure related to potential delisting from the exchange.
Response: In response to the Staff’s comment, the Company has revised its disclosures on the cover page of the Amended Registration Statement.
U.S. Securities and Exchange Commission
January 20, 2023
Page 2
Status of Previously Announced Acquisitions, page 67
2. Please update disclosure regarding the VIA Motors transaction to accurately reflect the current status of the transaction.
Response: In response to the Staff’s comment, the Company has revised its disclosures on page 69 of the Amended Registration Statement.
Executive Compensation, page 94
3. Please update disclosure to include compensation information for the year ended December 31, 2022.
Response: In response to the Staff’s comment, the Company has revised its disclosures beginning on page 96 of the Amended Registration Statement.
We hope that the foregoing and the Company’s revised disclosures have been responsive to the Staff’s comments. Should you have any questions or comments relating to this letter, kindly contact the undersigned at 212-503-9812.
Very truly yours,
/s/ William N. Haddad
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filename1.htm
T 212.503.9812
F 212.307.5598
wnhaddad@venable.com
January 20, 2023
VIA EDGAR
U.S. Securities and Exchange Commission
Division of Corporation Finance
Office of Manufacturing
100 F Street, N.E.
Washington, DC 20549
Attention: Eranga Dias
Asia Timmons-Pierce
Re: Ideanomics, Inc.
Registration Statement on Form S-1
Filed December 23, 2022
File No. 333-269001
Ladies and Gentlemen:
On behalf of our client, Ideanomics,
Inc. (the “Company”), we submit this letter setting forth the responses of the Company to the comments provided by
the staff (the “Staff”) of the Division of Corporation Finance of the Securities and Exchange Commission in its comment
letter dated January 19, 2023 (the “Comment Letter”) with respect to the above-referenced Registration Statement on
Form S-1 (“Registration Statement”). In response to the Comment Letter, the Company is filing Amendment No. 1
to the Registration Statement (the “Amended Registration Statement”) through EDGAR.
For your convenience, we have
set forth each comment of the Staff from the Comment Letter in bold type below followed by the Company’s response thereto.
Registration Statement on Form S-1 Filed 12/23/2022
Cover Page
1. Please disclose that you have received a notice from Nasdaq indicating that the company was no longer
in compliance with the audit committee requirements as set forth in Nasdaq Listing Rule 5605. Please provide an update on the status of
this notice. Please also disclose the status of the notice of non-compliance with the Nasdaq requirements pertaining to the minimum bid
price for listed stock pursuant to Nasdaq Listing Rule 5550(a)(2). Please also add risk factor disclosure related to potential delisting
from the exchange.
Response: In response to the
Staff’s comment, the Company has revised its disclosures on the cover page of the Amended Registration Statement.
U.S. Securities and Exchange Commission
January 20, 2023
Page 2
Status of Previously Announced Acquisitions,
page 67
2. Please update disclosure regarding the VIA Motors transaction to accurately reflect the current status
of the transaction.
Response: In response to the
Staff’s comment, the Company has revised its disclosures on page 69 of the Amended Registration Statement.
Executive Compensation, page 94
3. Please update disclosure to include compensation information for the year ended December 31, 2022.
Response: In response to the
Staff’s comment, the Company has revised its disclosures beginning on page 96 of the Amended Registration Statement.
We hope that the foregoing
and the Company’s revised disclosures have been responsive to the Staff’s comments. Should you have any questions or comments
relating to this letter, kindly contact the undersigned at 212-503-9812.
Very truly yours,
/s/ William N. Haddad
William N. Haddad
cc: Alfred P. Poor, Ideanomics, Inc.
Stephen Johnston, Ideanomics, Inc.
Paula Whitten-Doolin, Ideanomics, Inc.